For UK nationals living in France, understanding how to transfer a pension fund from the UK to France has become an important part of long term financial planning. Whether you have a workplace pension, a personal pension or several pots left behind in the UK, the rules that govern transfers, taxation and access can be complex. Pension transfer rules can differ significantly across EU jurisdictions, making it crucial for UK nationals moving to France to understand how local regulations and residency status affect their options and obligations. The right approach can secure better tax efficiency, smoother administration and a retirement income that aligns with your life in France.

This guide breaks down the key considerations, common questions from UK residents in France and how the UK France tax treaty influences your pension strategy. The European Union’s regulatory environment, especially after Brexit, has introduced new challenges and considerations for pension transfers, including the application of the UK’s 25% overseas transfer charge (OTC) for residents in certain EU countries.

Managing pensions across more than one country can be complex, so it is essential to understand the multi-country tax and legal considerations involved in cross-border pension transfers.

Introduction to Pension Schemes

When considering retirement options, particularly for UK expats living in France, understanding the various pension schemes available is crucial. A UK pension can be transferred to an overseas pension scheme, but it’s essential to navigate the complexities of the overseas transfer charge (OTC) and ensure compliance with UK and French regulations. For those looking to transfer their UK pension to France, it’s vital to explore the options for pension savings and pension income.

Pension funds can be transferred to a Qualifying Recognised Overseas Pension Scheme (QROPS), which offers tax benefits and flexibility in managing pension savings. However, France is not on HMRC’s list of recognised overseas pension schemes, making direct transfers to a French pension scheme challenging. Instead, UK expats may consider transferring their pension to an EU-based QROPS or exploring alternative options like a Self-Invested Personal Pension (SIPP).

UK registered pension schemes, such as defined benefit and defined contribution pensions, have different rules and regulations. Defined benefit pensions, also known as final salary pensions, provide a guaranteed income based on years of service and final salary. In contrast, defined contribution pensions, like SIPPs, offer more flexibility in investment options and pension income.

For British expats living in France, it’s essential to consider the tax implications of pension transfers and income. French income tax and social charges apply to pension income, but there are tax benefits and exemptions available. The double taxation agreement between the UK and France ensures that pension income is not taxed twice, but it’s crucial to understand the tax rules and regulations in both countries.

When transferring a UK pension to France, it’s vital to work with a financial adviser who is knowledgeable about UK and expat pension regulations. They can help navigate the complexities of pension transfers, including the overseas transfer allowance, and ensure that the chosen pension scheme is suitable for individual circumstances. By seeking professional advice, UK expats can make informed decisions about their pension savings and ensure a secure retirement in France.

In the next section, we will explore the options for transferring a UK pension to France, including the use of QROPS and SIPPs, and discuss the tax implications and benefits of each option. We will also examine the importance of seeking professional advice and the role of financial advisers in navigating the complexities of pension transfers.

Can I Transfer My UK Pension to France

The first question most British expats and UK expatriates ask is whether it is possible to move a UK pension fund directly into a French system. In practical terms, there is currently no straightforward route to transfer a UK pension into a French pension wrapper. France does not operate a recognised overseas pension scheme that accepts direct UK transfers. France is not included on HMRC’s QROPS list, which prevents direct transfers to French schemes.

French schemes, such as the plan d’épargne retraite populaire (PERP), were previously recognized as QROPS but were removed from HMRC’s list due to non-compliance with required UK pension rules. French schemes are considered long-term savings products or trusts, but they do not meet the required UK pension rules for overseas schemes, especially post-Brexit.

However, there are still efficient and fully compliant solutions to consolidate or restructure your pension for life in France. These include the use of an International SIPP or, in some cases, a QROPS based in an EU country that meets strict HMRC requirements. QROPS transfers involve a process that requires careful consideration of residency status, tax implications, and ensuring you are living in the same country as the QROPS to avoid the 25% overseas transfer charge. Understanding the rules for transferring existing UK pensions to overseas schemes is essential, as is compliance with both UK regulations and the rules of the country where the QROPS is based.

What happens to your pension if you leave the UK remains fully dependent on the type of scheme you hold. Defined contribution pensions remain accessible worldwide, while defined benefit schemes require specific advice due to their complexity and transfer restrictions. Required UK pension rules determine which overseas schemes are eligible for transfers. If you wish to transfer your UK pension, be aware of the complexities and legal restrictions involved, especially for British expatriates and UK expats living in France.

When exploring your options, key considerations include understanding the process to transfer your pension overseas, the role of your UK pension provider in facilitating or restricting overseas transfers, and the importance of understanding UK regulations when considering a transfer. The possibility to transfer your pension overseas depends on compliance with both UK regulations and the rules of the same country where the QROPS is based.

When exploring your options, key considerations include:

• The impact of the UK France double taxation agreement
• Whether the 10 year rule for QROPS applies to your situation
• Currency flexibility between sterling and euros
• Future retirement location
• Whether you intend to transfer your pension to another country in the future

Can I Have My UK Pension Paid into My French Bank Account?

Yes. You can receive your UK pension income directly into your French bank account. Your pension provider plays a key role in arranging international payments and may have specific restrictions or requirements for transferring your pension abroad. Most UK providers offer international payments although fees may apply and currency fluctuations can affect the final amount received. The money paid from your pension pot into your French account can also be subject to additional charges or deductions, so it is important to check with your provider.

This is where an International SIPP becomes useful, allowing you to hold your pension in multiple currencies and control when you convert sterling to euros. International SIPPs also offer the flexibility of ad hoc withdrawals, so you can pay yourself from your pension pot as needed, helping you manage your retirement income efficiently. This can significantly reduce the impact of exchange rate volatility on your long term income.

What Happens to My UK State Pension If I Move to France

Your UK State Pension continues to be paid when you move abroad and France is one of the countries where your State Pension remains uprated each year. This means you receive the annual increase as if you were still living in the UK.

You can have it paid into your French bank account or a UK one, depending on your preference.

Several related questions often follow.

Can you get National Insurance money back if you leave the UK?

In most cases no, but you can fill gaps to maximise your State Pension entitlement.

Which country is best to retire with a UK pension?

France remains attractive for many because of the tax treaty and high quality of life.

Is there a double taxation agreement between France and the UK?

Yes. This ensures your pension income is not taxed twice.

How Is My UK Pension Taxed in France

Your UK private pensions are usually taxable in France if you are a French tax resident. The UK France double taxation agreement allocates taxing rights to France to prevent double taxation.

Some pension withdrawals or inheritances can be tax free under certain conditions, such as if the individual dies before age 75, allowing beneficiaries to inherit the pension tax free.

This includes:

• Personal pensions
• Workplace pensions
• SIPPs
• Annuities

Your UK provider may still apply emergency tax if not informed properly, however this can typically be reclaimed.

France taxes pension withdrawals under the income tax system but also offers several allowances and reductions depending on your age and circumstances. For tax purposes, it is important to consider how withdrawals are structured, especially for those with complex estate planning needs. If you take a lump sum, be aware that a specific tax charge may apply, which can differ from the tax treatment of regular withdrawals.

Understanding how to avoid unnecessary tax involves reviewing:

• Whether lump sums are treated differently from regular withdrawals
• The 30 percent flat tax rule in France for investment income
• How to avoid the 60 percent tax trap in the UK for high earners before transfer
• Whether the 5 year QROPS rule affects lifetime allowance protections

If you remain UK domiciled, your pension fund may still be subject to UK tax and UK inheritance tax, so it is important to consider the impact of these on your estate. Ill health can also qualify individuals for special tax treatment or early access to pension funds, which may affect your withdrawal options.

Expert advice helps ensure you structure withdrawals efficiently and avoid avoidable tax liabilities.

Should You Consider a QROPS

A QROPS is no longer a mainstream solution for British expats in France. In reality, it is only a viable option if you live in the same jurisdiction as the QROPS scheme. For example, if the QROPS is based in Malta, you would need to be resident in Malta for the transfer to avoid the 25 percent Overseas Transfer Charge. If you live in France, or any country outside the jurisdiction of the scheme, HMRC will apply the 25 percent charge, which immediately removes most of the potential benefits.

This rule alone makes QROPS unsuitable for the majority of UK nationals who have settled permanently in France. For a French resident, an International SIPP typically offers a far more appropriate solution. It provides full FCA regulation, greater flexibility, no overseas transfer charge, transparent fee structures and multi currency capability.

A QROPS may still be relevant in very specific circumstances, such as when someone plans to relocate to the jurisdiction where the QROPS is held or has highly complex estate planning needs that require a bespoke structure. Outside of these narrow cases, most British expats in France are better served by an International SIPP that aligns with both UK and French regulatory frameworks and supports long term cross border retirement planning.

What Does It Typically Cost to Transfer a UK Pension

Costs vary depending on the provider, the advisory service and whether the pension is defined benefit or defined contribution. Defined benefit transfers require a UK regulated transfer specialist and involve a formal analysis of the risks.

For defined contribution schemes, costs usually relate to financial advice, new provider fees and potential transfer fees from your existing pension.

It is important to use transparent, fee based advisers who specialise in cross border planning for UK expats in France.

FAQs – Transfer Pension Fund from the UK to France

Can non residents open a bank account in France?

Yes, although it can be more complex and some banks require proof of French address.

Does the UK have a pension agreement with France?

Yes. The tax treaty and social security coordination rules allow pension rights to be recognised and prevent double taxation.

Which countries freeze UK pensions?

Countries without a reciprocal social security agreement. France is not one of them so your State Pension is uprated annually.

Can I move my retirement fund to another country later?

Yes. Many expats use an International SIPP for global mobility.

Speak to an International Pension Specialist

Transferring a pension fund from the UK to France, or preparing your pension for life in France, requires careful planning. Harrison Brook helps expatriates structure their pensions efficiently, comply with both UK and French rules and secure a sustainable retirement income.

Contact Harrison Brook today for a free initial consultation and personalised pension analysis.