Your UK pension when emigrating from the UK to France

If you're moving from the UK to France, one of the first money questions is what happens to your pension. The destination system here is French pension / assurance-vie.

Can you transfer a UK pension into French pension / assurance-vie?

Since Brexit, transferring a UK pension into an EEA QROPS can trigger HMRC's 25% Overseas Transfer Charge unless you're resident where the QROPS is based (France has few domestic QROPS, so Malta QROPS are sometimes used — complex, not always worth it). Most leave the pension in the UK. France taxes residents on worldwide income and has a property wealth tax (IFI); the UK-France treaty governs how pensions are taxed. Specialist advice is essential.

The 25% overseas-transfer charge

HMRC can apply a 25% Overseas Transfer Charge to a UK pension moved into a QROPS that doesn't meet the exemption conditions. Getting this wrong is one of the most expensive mistakes in the whole move — model it before you transfer anything.

Your real options

• Leave it invested in a UK SIPP or workplace scheme and draw it later — usually the simplest, and often the best.
• Where a compliant QROPS exists in France, transfer after taking advice on the overseas-transfer charge and the destination's tax treatment.
• A blend — consolidate UK pots into one SIPP now, decide on transferring once you're settled and the tax picture is clear.

Decide what happens to your pension before you move money — the right answer is tied to your UK residence status, your age, and whether France has a QROPS-registered scheme.