Wealth Management | Employee Benefits | Financial Behaviour

Transferring a UK pension overseas: what's actually changed, and the questions worth asking before you sign anything

Written by Sam Instone | 30 Nov 2025, 20:00:00

I get asked some version of this question most weeks: should I move my UK pension abroad now that I've settled in Dubai?

The honest answer is that it depends entirely on the pension you hold, your retirement plans, and a set of rules that have shifted substantially in the past two years.

It also depends on who's asking the question.A genuinely independent adviser starts by establishing whether you should transfer at all.

Plenty of the people offering this advice in Dubai start from the opposite end: they have a product to sell, and the recommendation tends to follow the commission rather than your circumstances. That's not a cynical aside.

It's the single biggest risk in this entire process, and it's worth understanding before anything else.

What is an overseas pension transfer?

An overseas pension transfer moves your UK pension savings out of a UK-registered scheme and into a qualifying scheme based outside the UK, most commonly when you relocate abroad permanently.

Done well, it can offer currency flexibility, easier local access, and in some cases tax advantages, particularly if the receiving scheme sits in a jurisdiction that taxes pension income lightly or not at all.

None of this is automatic.

Whether a transfer genuinely benefits you depends on the type of pension you currently hold, where you intend to retire, and what you'd be giving up by moving away from a UK-registered scheme.

The right starting point is proper retirement planning, not a product recommendation arriving before anyone has understood your situation.

Why this decision looks different than it did a few years ago

If you've read anything about QROPS or overseas pension transfers that predates 2024, treat the detail with real caution. Three changes since then have reshaped the calculation.

The lifetime allowance, the cap that used to trigger a steep tax charge once your pension exceeded roughly £1.073 million, was abolished in April 2024. Avoiding it used to be one of the strongest arguments for transferring into a QROPS. That argument, in its old form, no longer exists, because the mechanism it relied on has gone.

The European Economic Area exemption from the 25% overseas transfer charge was removed in the October 2024 Budget. This has limited bearing on a transfer made while you're resident in Dubai and transferring into a UAE-appropriate scheme, but it matters considerably if your QROPS already sits in an EEA jurisdiction like Malta and you've since moved, or might move again.

Most significantly, from 6 April 2027, most unused pension funds and death benefits, whether held in a UK pension or a QROPS, will be brought into the scope of UK inheritance tax. This directly reverses one of the strongest selling points used to promote overseas pension transfers for the past decade.

We'll come back to this, because for estate planning purposes it changes almost everything.

What replaced the pension lifetime allowance, and does it still affect a transfer?

The lifetime allowance was abolished on 6 April 2024 and replaced with a lump sum allowance of £268,275 and a lump sum and death benefit allowance of £1,073,100, which together cap how much tax-free cash you can take, rather than capping the overall size of your pension pot.

Transfers to a QROPS are now tested separately against an overseas transfer allowance, also set at £1,073,100.

Transfer more than your available allowance, and a 25% charge applies, but only to the excess above that figure, not the whole transfer.

HMRC's Pensions Tax Manual on overseas transfers sets this out in full. If your pension is meaningfully below this threshold, the old lifetime-allowance argument for transferring barely applies to you anymore.

What is a QROPS, and how does it differ from leaving your pension in the UK?

A Qualifying Recognised Overseas Pension Scheme is, structurally, very similar to a UK self-invested personal pension: a defined contribution scheme, but based outside the UK.

It must be regulated as a pension scheme, and recognised for tax purposes, in the country where it's established, and it must meet a specific set of requirements HMRC publishes and reviews regularly.

QROPS are intended for people who have left, or are firmly planning to leave, the UK, and they can theoretically offer genuine tax efficiency if the jurisdiction taxes pension income lightly.

The key word there is theoretically.

Whether a QROPS actually benefits you depends entirely on the type of pension you currently hold and what you'd sacrifice in the move, not on a generic comparison between two product categories.

We've covered the detailed differences between QROPS, QNUPS and SIPPs, and where each genuinely fits, in a separate piece worth reading before you go any further.

Before QROPS is even the right question: what kind of pension do you have?

There are two broad categories of UK pension, and the distinction matters enormously.

Defined benefit schemes, often called gold-plated pensions, guarantee an income for life and have become increasingly rare because of how expensive they are for employers to fund. If you have one, the starting position should be real scepticism about transferring out of it.

UK law requires anyone considering a transfer from a defined benefit scheme worth more than £30,000, including into an overseas QROPS, to take advice from an adviser specifically authorised by the Financial Conduct Authority to give UK pension transfer advice.

That requirement exists precisely because these transfers have, historically, gone badly for a lot of people sold the promise of flexibility without being shown clearly what they were giving up.

Defined contribution schemes carry no such guarantee. What you eventually receive depends purely on contributions and investment performance, and this is where the genuine QROPS-versus-staying-put comparison applies.

The rules that actually govern an international pension transfer

A handful of mechanical rules apply to almost every transfer, regardless of destination.

Eligibility requires that you're genuinely moving abroad and transferring into a recognised overseas scheme meeting HMRC's requirements.

Not every UK pension qualifies for transfer in the first place; most unfunded public sector schemes, for instance, are simply non-transferable, so this needs confirming with your current provider before anything else proceeds.

Tax compliance means understanding the overseas transfer charge properly. A 25% charge can apply unless you're tax resident in the same country as the QROPS at the time of transfer, the QROPS is a genuine occupational scheme sponsored by your multinational employer, or specific other narrow exemptions apply.

For a Dubai-based transfer into a UAE-appropriate scheme, residency alignment is usually the relevant exemption, but it must hold both at the point of transfer and for a defined period afterward, since moving country again within that window can retrospectively trigger the charge. The current detail sits in HMRC's guidance on reporting a QROPS transfer.

Reporting obligations run for longer than most people expect. Both the transferring UK scheme and the receiving QROPS may have reporting duties to HMRC for up to ten years after the transfer, and withdrawals made within five years of transferring, in some circumstances, can still be assessed against UK tax rules.

This isn't a transfer-and-forget decision.

How an international pension transfer actually proceeds

The mechanics, stripped of sales language, are straightforward, even if the underlying decision isn't.

First, confirm your pension's eligibility with your current provider; most defined contribution pensions can transfer, but defined benefit schemes carry restrictions and statutory advice requirements.

Second, identify whether a suitable scheme actually exists for your circumstances; not every QROPS is HMRC-compliant, the list of recognised schemes changes regularly, and some popular destinations now have very few, or no, active options, which means staying in a UK SIPP is sometimes simply the better answer by default.

Third, understand the tax position properly, both the UK overseas transfer charge and how your country of residence will treat the pension once it lands.

Fourth, get advice from someone whose income doesn't depend on you transferring.

On timing, a UK-to-QROPS transfer typically takes eight to twelve weeks from start to finish, sometimes longer, depending on how responsive your current and receiving providers are, whether any documents or identity checks are outstanding, and whether your existing provider still relies on paper-based processing rather than digital systems.

None of this should be rushed to meet an adviser's quarter, which is, regrettably, a real pressure that exists in this industry.

For the wider context on whether transferring makes sense for your specific situation as a Dubai-based senior professional, our piece on QROPS versus SIPP for Dubai executives walks through a real client case in detail.

Why this market attracts so much bad advice

A transfer can genuinely benefit some people. It's also one of the most heavily marketed, over-sold, and at times mis-sold areas of expat financial planning anywhere in the world, and Dubai has a particularly active market for it.

Some transfers generate substantial commissions for the adviser arranging them, and those commission payments come, directly or indirectly, out of your pension.

This creates an obvious incentive problem: the person advising you on whether to transfer often profits only if you do.

Getting a transfer wrong, whether through poor advice or an unsuitable receiving scheme, can also trigger a significant HMRC tax penalty if the transfer is later judged unauthorised.

Taking regulated, qualified, genuinely unconflicted advice isn't a nice-to-have here.

It's the single factor most likely to determine whether this decision helps or seriously damages your retirement - the pension transfer specialist accreditation carries a binding code of ethics requiring them to act in your best interest, not merely within the letter of the regulations.

This is precisely the standard a properly regulated wealth management adviser in Dubai should be held to before they're anywhere near your pension.

How a transfer affects your UK tax position

The tax consequences of transferring depend on several variables working together: the type of pension, the destination scheme, and your residency status both now and in the future.

Transferring to a compliant QROPS doesn't itself trigger UK tax, beyond the overseas transfer charge where it applies.

Once you're genuinely living abroad, UK tax generally won't apply to withdrawals unless you return and become UK resident again, though your country of residence will have its own view, and where a double taxation agreement exists with the UK, it should prevent the same income being taxed twice, provided the relief is claimed correctly.

We go into this question specifically, whether expats pay tax on a UK pension while living overseas, in more depth elsewhere.

You can still take a tax-free lump sum from a UK pension from age 55, rising to 57 from April 2028, regardless of where you live, capped at the lump sum allowance described earlier. That said, tax-free cash from UK pensions is not universally recognised, and some countries may charge local taxes on withdrawals, even if the UK doesn’t. It’s important to consult your financial planner and/or local tax adviser before accessing your pension benefits.

If you're transferring a defined benefit scheme specifically, remember the transfer itself usually isn't taxed, but you may be giving up valuable guarantees, like inflation-linked income for life, that are extremely difficult and expensive to replicate elsewhere.

That loss needs weighing as carefully as any tax consideration.

The change that overturns the old QROPS sales pitch: pensions and inheritance tax

For years, one of the headline arguments for transferring a UK pension into a QROPS was that it could pass to your beneficiaries free of UK inheritance tax, in contrast to a UK pension potentially facing a 40% charge. That argument needs retiring.

From 6 April 2027, most unused pension funds and death benefits, whether held in a SIPP or a QROPS, will be brought within the value of the deceased's estate for UK inheritance tax purposes.

The existing exemption for benefits passing to a surviving spouse or civil partner, and to registered charities, remains, but outside of that, the gap between a SIPP and a QROPS on this specific point is narrowing substantially. HMRC's technical note on inheritance tax and pensions sets out exactly how this will work.

If you've been told a QROPS keeps your pension outside UK inheritance tax permanently, that claim needs revisiting before you act on it.

What's genuinely true, and what's overstated, about transferring abroad

Stripped of marketing language, here's a fair accounting.

Real, durable advantages include currency flexibility, since a UK pension is paid in sterling and exposes you to exchange rate risk if you're spending in dirhams or another currency, and access to a scheme genuinely structured for your country of residence, which can simplify both administration and local tax compliance.

If your destination country has a proper double taxation agreement with the UK, you may also avoid UK tax deductions at source, paying tax only locally.

Genuine risks include the 25% overseas transfer charge where exemptions don't apply, the loss of UK protections like Financial Services Compensation Scheme cover once your pension sits outside the UK system, and local tax exposure in your country of residence that catches people off guard, particularly if you later move somewhere with less favourable pension tax treatment than the UAE.

Fees also deserve scrutiny: advice is typically 1 to 3% of the transfer value, scheme setup can run from a few hundred to over a thousand pounds, and annual administration and platform fees commonly sit between 0.5% and 2%, before any currency conversion costs.

None of these costs are necessarily unreasonable, but they need disclosing in full and weighing honestly against the benefit, which is exactly the conversation a commission-driven adviser has limited incentive to have transparently.

What happens to your pension or QROPS when you die?

This depends first on whether you hold a defined benefit or defined contribution pension.

Defined benefit schemes follow whatever the scheme's own rules say, and these vary considerably from scheme to scheme, sometimes leaving very little for a spouse or adult children.

Defined contribution schemes, including most SIPPs and QROPS, are generally more flexible about who receives the remaining fund, and historically the tax treatment for beneficiaries has depended on your age at death and whether income tax applies to what they receive.

As covered above, the inheritance tax position itself is changing materially from April 2027, so any assumptions here, including ones in older AES material, deserve a fresh look rather than being taken at face value.

Where this leaves you

Whether to transfer a UK pension overseas was never a yes-or-no question with a generic answer, and it's become more nuanced, not less, over the past two years.

The lifetime allowance argument has gone.

The inheritance tax argument is reversing.

What remains genuinely relevant, currency flexibility, local tax alignment, and proper coordination with the rest of your financial planning, still deserves serious consideration.

It just needs weighing against current rules, not the version of this decision that was true five years ago.

If you'd like an honest second opinion on whether to transfer a UK pension, book a 15-minute discovery call.