QROPS and the overseas transfer charge for residents of France

You live in France and someone has suggested moving your UK pension into a QROPS. Before the first form is signed, three facts decide most cases: what the overseas transfer charge now costs from France, whether any exclusion still reaches you, and what keeping the pension in the United Kingdom, in its current scheme or in a SIPP, would give you instead.

A QROPS, a qualifying recognised overseas pension scheme, is an overseas pension scheme that meets the UK conditions for receiving a transfer from a registered UK pension scheme. If you live in France and hold a UK pension, the question is rarely whether such a scheme exists but what the transfer now costs, compared with keeping the UK scheme or consolidating into a SIPP that stays in the United Kingdom.

In short

A resident of France who transfers a UK pension to a QROPS, a qualifying recognised overseas pension scheme, pays the 25% overseas transfer charge unless an exclusion applies: under Section 32 of the Finance Act 2025, the European exclusion no longer applies to a transfer requested from 30 October 2024 or completed from 30 April 2025.
The remaining exclusions are residence in the country where the QROPS is established (section 244B) and the employer, overseas public service and international organisation schemes (sections 244D to 244F of the Finance Act 2004); each depends on information given before the transfer, and the charge still applies above your overseas transfer allowance. HMRC’s list of 1 October 2026 contained no scheme established in France, so the residence exclusion is out of reach from France.
Only the residence exclusion has to be kept after the transfer, for the relevant period, which runs from the transfer to the following 5 April and then for five full tax years: if you stop meeting it within that period, the charge arises at that moment. The employer, public service and international organisation exclusions are tested on the date of the transfer.
Once you have asked your UK scheme for the transfer, you have 60 days to give its administrator the information it needs and a signed acknowledgement, on HMRC form APSS263 or the scheme’s own paperwork; without them before the transfer, the administrator deducts the charge. Form APSS255 plays the same role, with the QROPS manager, for a later transfer from one QROPS to another.
Consolidating your pots in a SIPP, a UK self-invested personal pension, is a transfer between two UK schemes on which the charge does not arise, and its payments are generally taxable in France under the France–UK convention of 19 June 2008.

The HMRC list, and what it does not say

HMRC publishes a list of overseas schemes that have told it they meet the conditions to be a recognised overseas pension scheme. HMRC states that it cannot guarantee these schemes are recognised, nor that a transfer to them will be free of UK tax, and it updates the list on the first and fifteenth of each month: the version dated 1 October 2026 added 46 schemes and removed 7. Responsibility for checking the receiving scheme rests with you, and a transfer to a scheme that turns out not to qualify is treated as an unauthorised payment, taxed as such by the United Kingdom on the member.

The list is organised by country, and on 2 October 2026 we read it for France: the only entry containing the word is an Australian scheme whose name happens to include it. No scheme established in France appears, which matters for the residence exclusion described below, and which is why the usual QROPS proposal made to a resident of France involves a scheme established in a third country, subject to that country’s rules on access, currency and fees.

The overseas transfer charge for a resident of France

The overseas transfer charge is a UK tax of 25% of the amount transferred, deducted by the transferring scheme, due on a transfer of UK tax-relieved pension savings to a QROPS unless the transfer falls within one of the exclusions set out in sections 244B to 244H of the Finance Act 2004 and stays within your overseas transfer allowance, the amount you may move abroad before the charge applies: Finance Act 2004, section 244AC ↗.

HMRC’s guidance names four exclusions, each of which requires the member to provide information before the transfer: you are resident in the country where the receiving QROPS is established; the QROPS is an occupational scheme and you are an employee of an employer sponsoring it at the date of transfer; the QROPS is an overseas public service scheme and you are employed by an employer participating in it; or the QROPS is the scheme of an international organisation that employs you at that date.

A fifth exclusion used to protect most transfers made from Europe: a scheme established in an EEA state or Gibraltar, where the member was resident in the United Kingdom or in an EEA state, was outside the charge. Section 32 of the Finance Act 2025 repealed it for transfers requested on or after 30 October 2024, saving only a transfer requested before that date and completed before 30 April 2025: Finance Act 2025, section 32 ↗.

For someone living in France, the practical result is that a transfer to a QROPS established in another European country now meets the charge unless one of the four employment or residence exclusions applies, and the residence exclusion asks for a scheme established in France, which the list did not contain on 1 October 2026.

An exclusion does not close the question. The charge still arises on the part of a transfer that exceeds your remaining overseas transfer allowance: Finance Act 2004, section 244IA ↗. And the residence exclusion rests on your circumstances during a period HMRC calls the relevant period, five full tax years from the transfer date, the rest of the tax year of the transfer being counted in addition: if you move to another country within that period and no longer meet the exclusion you relied on, the charge is treated as arising at that moment, and the scheme manager must report the change to HMRC: Finance Act 2004, section 244B ↗.

The exclusions for an employer’s scheme, an overseas public service scheme and an international organisation’s scheme are tested at the date of the transfer instead: leaving that employment afterwards does not bring the charge. A transfer made under the former European exclusion keeps its own relevant period: moving to another EEA country or to the United Kingdom leaves it sheltered, moving elsewhere brings the charge on the date of the move.

The same period works the other way. A charge becomes repayable when, within the relevant period, your circumstances change so that the transfer would have been excluded: you become resident in the scheme’s country, you become an employee of an employer taking part in the receiving scheme, or you supply the information whose absence alone caused the charge.

HMRC repays only the person who paid the charge, and on a request from that person: the UK scheme administrator on form APSS242 when it deducted the charge at the transfer, the manager of the QROPS on form APSS243 when the scheme paid it. Money repaid to a scheme goes back into a pension scheme, not to you: HMRC, PTM102600 ↗.

At the transfer, the UK scheme administrator and you are jointly liable for the charge; where it arises later because your circumstances change, you and the manager of the QROPS that holds the funds are. When you ask your UK scheme to transfer your pension, its administrator should tell you within 30 days what it needs, and you must give it, within 60 days of the request, the information that decides whether the charge applies, with a signed acknowledgement: HMRC’s form APSS263 ↗ can be used, or the scheme’s own paperwork.

If you do not give them before the transfer is made, the administrator deducts the charge, and if the 60 days pass the request can lapse and has to be made again. Form APSS255 is the equivalent, given to the manager of your QROPS, for a later transfer from one QROPS to another. Because the request starts these 60 days, the comparison between keeping and moving the pension is best made before you send it.

QROPS or SIPP when you live in France

A SIPP, a self-invested personal pension, is a UK registered scheme. Moving your pots into a SIPP is a transfer between two UK schemes, not an overseas transfer, so the overseas transfer charge does not arise, the UK rules on access and on regulated advice for guaranteed benefits continue to apply, and the pension is simply drawn from France.

For a French tax resident, payments from a UK private pension are generally taxable in France under the France–UK convention of 19 June 2008, and the French treatment of a one-off payment of all or part of the pot, known as a lump sum, has its own rules, set out in UK pensions and SIPPs for French tax residents.

With a QROPS, your pension is paid by a scheme in a third country. The tax convention between France and that country governs the payments, not the France–UK convention, so the treaty analysis has to be redone for the scheme’s country before any conclusion is drawn about French tax.

The arrangement itself needs a French reporting review: its legal form and documents establish whether a declaration is required under article 1649 A or 1649 AA of the French tax code, and where one is required, the absence of a withdrawal does not remove it. The fees of the receiving scheme, its administrator and any underlying investment platform add a layer that a UK scheme does not have.

A QROPS transfer still has a case in three situations that the legislation itself describes: you are, or will be for the whole relevant period, resident in the country where the scheme is established; the scheme belongs to your employer, to a public service you work for or to an international organisation that employs you; or the transfer was requested before 30 October 2024 and completed before 30 April 2025 under the former European exclusion, in which case the question is how that past transfer is read rather than whether to make a new one.

Outside those situations, a resident of France who is offered a QROPS should ask the proposer to write down the charge, the exclusion relied on and the allowance position before anything else is discussed.

What we check before you instruct a transfer

We verify the French side: your residence date, how the convention with the scheme’s country allocates the right to tax the payments, how France would tax a regular payment and a lump sum, and which reporting obligations the arrangement creates from the first French return.

On the UK side, we coordinate with the adviser holding the relevant UK permission, whose involvement is required by law where guaranteed benefits above the statutory threshold are given up, and we ask the receiving scheme for its written confirmation of the charge and of the exclusion it relies on. The firm coordinates the parties and verifies the French treatment; it does not replace any of them, and it does not recommend a transfer whose cost has not been written down.

The information to gather

The scheme documents and a current valuation for each UK pension, with any guaranteed benefits identified. Your residence history and the country you expect to live in during the relevant period. Your employment, if the proposed scheme is linked to an employer, a public service or an international organisation. The receiving scheme’s written statement of the overseas transfer charge, the exclusion relied on and the allowance used. And the fee schedule of the receiving scheme, its administrator and its investment platform, line by line.

This page describes general mechanisms and does not recommend a transfer. The two UK parameters it reproduces, the rate of the overseas transfer charge and the length of the relevant period, were read on GOV.UK on 2 October 2026 and are revised by UK finance legislation: they must be checked again at the date of the operation, as must the HMRC list, which changes twice a month.

Before transferring a UK pension, check the guarantees attached to it and whether regulated UK advice is required: Pension Schemes Act 2015, section 48 ↗. Where advice is required, it must come from an adviser with the relevant UK permission. The French treatment described here depends on the convention applicable to the scheme’s country and on your personal situation.

References cited

HMRC — Overseas pensions: pension transfers (overseas transfer charge, exclusions, relevant period, refunds) · HMRC — Recognised overseas pension schemes notification list (updated 1 October 2026) · HMRC Pensions Tax Manual PTM102300 — the exclusion conditions (read 4 October 2026) · HMRC Pensions Tax Manual PTM102400 — a charge arising after the transfer (read 4 October 2026) · HMRC Pensions Tax Manual PTM102900 — information to be provided before the transfer (read 4 October 2026) · HMRC — form APSS263, member information for the UK scheme administrator before a transfer to a QROPS (updated 22 January 2025, read 6 October 2026) · HMRC Pensions Tax Manual PTM102600 — repayment of the overseas transfer charge (read 6 October 2026) · HMRC — form APSS255, member information for the scheme manager of a QROPS before a transfer to another QROPS · Finance Act 2004, section 244AC — overseas transfer charge · Finance Act 2025, section 32 — repeal of the EEA and Gibraltar exclusion

Frequently asked questions

What is a QROPS?

A qualifying recognised overseas pension scheme: an overseas pension scheme that meets the UK conditions for receiving a transfer from a registered UK pension scheme without the transfer being taxed as an unauthorised payment. HMRC publishes a list of schemes that have told it they meet the conditions, updated on the first and fifteenth of each month, and states that it cannot guarantee any of them, so checking the receiving scheme on the day of the transfer remains the member’s responsibility.

Is there a QROPS in France?

Not on HMRC’s list dated 1 October 2026, read on 2 October 2026: the only entry containing the word France is an Australian scheme. A resident of France who transfers to a QROPS therefore moves the pension to a scheme established in a third country, and the residence exclusion from the overseas transfer charge, which requires living in the scheme’s country, is out of reach from France for as long as that remains true.

Do I pay the overseas transfer charge if I live in France and transfer to a QROPS?

In most cases yes, at 25% of the amount transferred, since the exclusion for schemes established in the European Economic Area no longer applies to a transfer requested on or after 30 October 2024 or completed on or after 30 April 2025. The charge is avoided only if you fall within one of the four remaining exclusions, residence in the scheme’s country or employment linked to the scheme, and only up to your overseas transfer allowance, the transferring scheme deducting the charge before the money moves.

QROPS or SIPP for someone living in France?

On the cost of the transfer, the SIPP: moving a UK pension into a SIPP is a transfer within the United Kingdom, so it does not give rise to the overseas transfer charge. When you live in France, transferring a UK pension to a QROPS bears that charge, 25% of the amount transferred, unless an exclusion applies: residence in the scheme’s country, or a scheme linked to your employer, to an overseas public service or to an international organisation. Even within an exclusion, the part of the transfer that exceeds your remaining overseas transfer allowance is charged at the same rate. The SIPP pension is then drawn from France under the France–UK convention; a QROPS moves it to a third country, with that country’s convention, fees and access rules. Compare the two in writing, with the guarantees you would give up in either case, before instructing anything.

How is a QROPS pension taxed in France?

As a pension paid from the scheme’s country: France taxes its residents on worldwide income under article 4 A of its tax code, subject to the convention between France and that country, which has to be read for the scheme’s jurisdiction rather than for the United Kingdom. The arrangement also needs a separate French reporting review. Its legal form and documents determine whether article 1649 A or 1649 AA applies; a reportable arrangement can require a declaration even when nothing has been withdrawn.

Can the overseas transfer charge be refunded?

Yes, in two cases: when it was paid in error, and when your circumstances change within the relevant period, which runs from the transfer to the following 5 April and then for five full tax years, in a way that would have excluded the transfer, for instance by becoming resident in the scheme’s country. HMRC repays the person who paid: the UK scheme administrator, on form APSS242, when it deducted the charge at the transfer, or the manager of the QROPS, on form APSS243, when the scheme paid it; the money goes back into a pension scheme, not to you. The same period can also make the charge arise after the event if you relied on the residence exclusion and leave the scheme’s country.

ÉTHIQUE ET PATRIMOINE, a French simplified joint-stock company (SAS), registered office at 41 rue Saint-Ferdinand, 75017 Paris, France, Paris Trade Register no. 803 414 796, VAT no. FR 40 803 414 796, registered with ORIAS under number no. 24001817 (www.orias.fr) — Financial investment adviser (CIF) no. 18002418, member of ANACOFI-CIF, a professional association approved by the Autorité des marchés financiers, and Anacofi-Courtage for its brokerage activity. Presence: Paris, Montpellier, London, Singapore, Hong Kong, Bangkok, Shanghai and Dubai.

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