The door has closed for expats wishing to transfer their UK retirement savings to an offshore pension.
Chancellor Rachel Reeves flagged that she was tightening the rules for switching UK pension funds to the offshore Qualifying Recognised Overseas Pension Scheme (QROPS).
The new rules take effect on April 6, 2025. They remove an exemption from the overseas transfer charge (OTC) when transferring money to a QROPS operating in the European Economic Area and Gibraltar (EEA).
Before April 6, expats living in one EEA country could open a QROPS in any other EEA country without incurring the OTC.
The new rules align EEA QROPS with those in the rest of the world, which say expats can only transfer to a QROPS operating where they live. Flouting the rule incurs an OTC charge of 25 per cent of the value of the fund transferred.
How the New QROPS Rules Work
For example, an expat in France, which currently has no QROPS, could open a QROPS in the Netherlands without incurring an OTC penalty. Now, an expat in France has no access to a QROPS pension.
HM Revenue and Customs says: “Aligning the treatment of transfers to QROPS established in the EEA and Gibraltar with that of transfers to QROPS established in the rest of the world will help to ensure that some UK residents do not benefit from a double tax-free allowance whilst remaining in the UK, and reduces the risk of around £1 billion of UK tax-relieved pension savings being transferred overseas across the scorecard.”
HMRC has benchmarked the rule change by issuing an unexpected QROPS List of active schemes.
However, the list is the same as the one published on April 1.
From April 1, 2025, expats, including a QROPS in their financial plans, must live in one of the countries listed in the table below and open a QROPS operating in that country to avoid the OTC.
HMRC QROPS List – By Country
| Country | QROPS |
| Australia | 2115 |
| Austria | 3 |
| Barbados | 1 |
| Belgium | 3 |
| Bulgaria | 2 |
| Canada | 7 |
| EU Institution | 1 |
| Germany | 6 |
| Gibraltar | 28 |
| Guernsey | 55 |
| Hong Kong | 12 |
| Iceland | 1 |
| India | 30 |
| Ireland | 37 |
| Isle of Man | 272 |
| Jersey | 91 |
| Kenya | 3 |
| Latvia | 4 |
| Luxembourg | 2 |
| Malta | 29 |
| Netherlands | 122 |
| New Zealand | 35 |
| Norway | 1 |
| Slovakia | 1 |
| Spain | 1 |
| Sweden | 2 |
| Switzerland | 2 |
| Uganda | 1 |
| Grand Total | 2867 |
Source HMRC
HMRC QROPS List – Top 10 Countries
Countries by number of QROPS listed offering the most QROPS
| Country | QROPS |
| Australia | 2115 |
| Isle of Man | 272 |
| Netherlands | 122 |
| Jersey | 91 |
| Guernsey | 55 |
| Ireland | 37 |
| New Zealand | 35 |
| India | 30 |
| Malta | 29 |
| Gibraltar | 28 |
| Grand Total | 2814 |
Source: HMRC
HMRC QROPS List – Changes
| QROPS | Country | Added | Removed |
| N\a | |||
| Totals: | 0 | 0 | |
| QROPS listed April 01, 2025 | 2864 | ||
| Net change since April 01, 2025 | 0 | ||
| QROPS listed April 06, 2025 | 2864 | ||
| Amended QROPS | Country | ||
| None | |||
| QROPS Jurisdictions | Added | Removed | |
| No change | 0 | 0 | |
| Totals: | 0 | 0 | |
| Countries with QROPS listed on April 01, 2025 | 28 | ||
| Net change since April 01, 2025 | 0 | ||
| Countries with QROPS listed April 06, 2025 | 28 | ||
| Next HMRC QROPS List due April 15, 2025 | |||
QROPS List FAQ
The QROPS List is an invaluable free tool for advisers and retirement savers seeking an expat pension.
However, the use of the data is often misunderstood, so here are the answers to some of the most
asked questions about QROPS expat pensions.
What is the QROPS List?
The HMRC list tells overseas pension providers and retirement savers transferring funds from the UK
pension to a QROPS or between offshore pension providers, and which schemes have certified that
they qualify for QROPS status.
QROPS providers certify their schemes meet UK offshore pension and tax rules to go on the list, but
HMRC warns this does not mean any are approved or sure to be QROPS.
So, retirement savers should check the latest QROPS list before transferring money.
What is the Overseas Transfer Allowance?
The Overseas Transfer Allowance (OTA) was introduced in April 2024 to replace the lifetime allowance (LTA) test on transfers to QROPS pensions.
The LTA test checked that transfers to QROPS did not exceed the now-abolished LTA.
The OTA caps the retirement savings someone can transfer to a QROPS at £1,073,100. If the transfer is more than the OTA, the Overseas Transfer Charge applies, a penalty of 25 per cent of the transferred fund.
QROPS Overseas Transfer Charge
The overseas transfer charge is 25 per cent of the transfer value of a fund moved into a QROPS or
between QROPS.
Expats opening a new QROPS must transfer their pension funds to a scheme based in their home country to avoid the OTC.
Other exceptions to the transfer charge may apply if an employer or multinational non-government
organisation runs the scheme, such as the EU QROPS.
A five-year residence rule may also apply.
The OTC is refundable should an expat’s circumstances change, but time limits may apply.
Click here for official guidance on the overseas transfer charge
Why does HMRC remove pensions from the QROPS List?
HMRC delists QROPS for several reasons, including:
- The provider closes
- The last pension member has left the scheme
- Tax avoidance issues
- The scheme stays a QROPS, but the provider invokes confidentiality
Delisting should not imply wrongdoing by a retirement saver or provider.
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