UK pensions and SIPPs for French tax residents

If you live in France and hold UK pensions or a SIPP, start by identifying each arrangement and the benefits you plan to take. Scheme rules, tax treatment and reporting need to be reviewed together before a withdrawal or transfer. This page sets out the questions to prepare for that discussion.

A UK private pension and a pension for government service may be treated differently under the France–UK tax convention of 19 June 2008. For a resident of France, private pensions are generally taxable in France. Government-service pensions have a separate rule and a nationality exception. Identify each scheme and whether you plan regular payments or a single payment of the whole pot, known as a lump sum, before calculating the result.

In short

A UK lump sum that France may tax follows article 163 bis, requested expressly and irrevocably where its conditions are met; the quotient of article 163-0 A, which cannot be combined with that request; or, failing both, the ordinary scale of article 79.
The overseas transfer charge is due on a transfer to a QROPS, a qualifying recognised overseas pension scheme, unless an exclusion in sections 244B to 244H of the Finance Act 2004 applies; HMRC’s list held no scheme established in France on 25 September 2026.
A UK pension held by a French resident may have to be reported under article 1649 A or 1649 AA of the French tax code; an unreported bank account carries a fine of €1,500 per account per year under article 1736 IV, and more where the state concerned has not concluded with France an administrative assistance agreement giving access to banking information.

What to prepare before a pension decision

A pension review should begin with the scheme documents and your intended use of the money. Avoid treating all UK retirement arrangements as though they were one account with one set of rules.

Identify the scheme, provider and type of benefits, including any guarantees described in the documents.
List withdrawals already taken and those you are considering.
Set out your residence history and the countries relevant to the proposed payment.
Before a transfer, obtain a written explanation of the charges, rights affected and advice required for that arrangement.

The type of scheme determines what can move

A defined contribution scheme, including a SIPP, holds investments from which benefits are paid. A defined benefit scheme promises benefits calculated under its rules and may provide increases and survivor protection. A transfer can give up those guarantees. The required UK advice depends on the benefits and their value, and must come from an appropriately authorised firm.

The state pension follows its own logic entirely. It cannot be transferred anywhere, it is paid abroad, and its annual uprating depends on the arrangements between the United Kingdom and your country of residence rather than on your own contribution record.

The French treatment of a UK lump sum

A UK tax exemption does not automatically exempt a payment in France. First establish how the treaty applies to the pension and the proposed withdrawal. If France may tax a retirement lump sum, three treatments are in play and they exclude one another: the levy of article 163 bis, which needs an express and irrevocable request and applies only where the capital is paid in one go and the contributions were deductible from taxable income or related to income exempt in the state that had the right to tax it; the quotient of article 163-0 A, which spreads an exceptional payment across the scale and cannot be combined with that request; and, failing both, the ordinary scale that applies to pensions under article 79. Which one applies is worth settling before you give the provider instructions, because the request under article 163 bis cannot be withdrawn.

Ask the provider to describe the proposed payment in writing, including its amount, the benefits remaining and any guarantees given up. This gives the French and UK advisers the same transaction to assess.

Keeping and paying into a SIPP after leaving the UK

Moving to France raises three separate questions. Keeping the SIPP depends on the scheme rules and on whether the provider keeps clients resident in France. Paying in depends on whether the provider accepts new contributions from a client living in France, which some providers do not. Tax relief on those contributions depends on UK law. Ask the provider in writing about the first two before or soon after the move.

UK tax relief on contributions is available only to a “relevant UK individual” under 75 (Finance Act 2004, section 188 ↗ and section 189 ↗). Living in France, you remain one for a UK tax year, which runs from 6 April to 5 April, if you have relevant UK earnings taxed in the UK that year, or if you were resident in the UK at some time during the five UK tax years immediately before it and when you joined the scheme.

Under section 190 ↗, relief is then limited each tax year to those UK earnings or, if they are lower or nil, to a basic amount of £3,600 gross; once those five tax years have passed, a member with no UK earnings receives no UK relief on new contributions.

Relief on the basic amount, when your UK earnings are lower than £3,600 or nil, can only be given through relief at source (section 191(7) ↗): you pay the contribution net of basic rate tax, and the scheme administrator reclaims that tax from HMRC under section 192 ↗. A scheme that does not operate relief at source cannot give it.

UK tax relief does not determine whether a contribution reduces your French taxable income. That French deduction needs a separate assessment and is not covered here; the section above explains the French treatment of a UK lump sum.

Considering a QROPS transfer

A Qualifying Recognised Overseas Pension Scheme is a non-UK scheme that meets the UK conditions for receiving a transfer from a registered UK scheme without that transfer being treated as an unauthorised payment. HMRC publishes a list of schemes that have told it they meet the conditions. That list is information, not approval: it does not amount to verification, and responsibility for checking rests with the member. A scheme can leave the list, and a transfer to a non-qualifying scheme becomes an unauthorised payment taxed as such.

A QROPS transfer needs a comparison of the existing scheme and the proposed receiving scheme. Include charges, guarantees, access to investments and the overseas transfer charge. Check the current HMRC requirements and any change of residence planned afterwards. A receiving scheme in another country adds rules to examine; it does not automatically make the transfer better or worse.

The overseas transfer charge shapes much of that comparison, because it is due on a transfer to a QROPS unless the transfer falls within one of the exclusions that sections 244B to 244H of the Finance Act 2004 set out and stays within the member’s overseas transfer allowance: Finance Act 2004, section 244AC ↗.

They cover, among others, a member who is resident in the country or territory where the QROPS is established, and a transfer to an occupational pension scheme where, at the time of the transfer, the member is an employee of an employer that sponsors that scheme: Finance Act 2004, section 244D ↗.

A third exclusion used to cover a scheme established in an EEA state or Gibraltar where the member was resident in the United Kingdom or in an EEA state. Section 32 of the Finance Act 2025 repealed it for transfers made on or after 30 October 2024, saving only a transfer made in execution of a request placed before that date and completed before 30 April 2025: Finance Act 2025, section 32 ↗.

Both dates have passed, so the saving now matters only when reading a transfer already made inside that window, and such a transfer keeps its relevant period: a move to another EEA country or to the United Kingdom leaves it sheltered, while a move elsewhere before the period ends brings the charge on the date of the move, according to HMRC’s Pensions Tax Manual (PTM102400).

For a resident of France, the residence exclusion is hard to reach, because it asks for a QROPS established in France. On 25 September 2026 HMRC’s notification list, published on 15 September, contained no scheme established in France. HMRC describes that list as schemes which have told it they meet the conditions, states that it cannot guarantee they are recognised overseas pension schemes or that transfers to them will be free of UK tax, and republishes it twice a month: check it again on the day the transfer is instructed.

Falling within an exclusion does not settle the question on its own. A transfer that is excluded still attracts the charge if its value exceeds the member’s remaining overseas transfer allowance, the amount that can be moved to overseas schemes before the charge applies: Finance Act 2004, section 244IA ↗.

The residence exclusion is also granted on an assumption about the years that follow: if the member stops being resident in that country before the end of the period the legislation sets, the exclusion falls away and the charge is treated as arising at that moment: Finance Act 2004, section 244B ↗. The rate of the charge, the four exclusions HMRC names, the refund procedure and the comparison with a SIPP are set out in QROPS and the overseas transfer charge for residents of France.

What has to be reported, whatever you decide

A UK pension arrangement held by a French resident may fall within article 1649 A of the French tax code, which covers accounts opened, held, used or closed abroad, or within article 1649 AA if it is analysed as a capitalisation contract or similar investment taken out with a provider established outside France. The fine for an unreported bank account under article 1736 IV is €1,500 per account per year, and it applies whether or not anything was drawn.

An unreported capitalisation or life assurance contract carries its own fine under article 1766, increased where the provider is established in a state that has no administrative assistance agreement with France. The characterisation is done on the scheme’s own documents; a SIPP and a trust-based occupational scheme do not necessarily land in the same place.

Reporting foreign accounts, policies and trusts in France sets out the four separate obligations in full. The wider changes Brexit made to what still works for a British portfolio are covered in Financial planning in France for UK nationals after Brexit.

The information needed for the review

Identify each scheme and the benefits it provides, the payment you are considering and your residence history. Confirm the reporting requirements and the UK advice needed for any transfer. Keeping the existing pension belongs in the comparison.

Before transferring a UK pension, check the guarantees attached to it and whether regulated UK advice is required. A final salary pension, a guaranteed minimum pension and a guaranteed annuity rate are examples of the rights known as safeguarded benefits.

The advice requirement depends on the proposed operation and the value of those rights: Pension Schemes Act 2015, section 48 ↗. The statutory check does not apply where their cash-equivalent value under the scheme is £30,000 or less: Transitional Provisions and Appropriate Independent Advice Regulations 2015, regulation 5 ↗. Where advice is required, it must come from an adviser with the relevant UK permission.

This page sets out general mechanisms and replaces neither the scheme rules nor the applicable treaty text. UK parameters such as charge rates, allowances and time limits are deliberately not reproduced: they are revised by finance legislation and must be checked at the date of the operation. The firm coordinates the parties and verifies the French treatment; it does not replace any of them.

References cited

CGI, art. 1649 A · HMRC — Check the recognised overseas pension schemes notification list · HMRC — Overseas pensions: pension transfers (overseas transfer charge) · GOV.UK — State Pension if you retire abroad: how your pension is affected

Frequently asked questions

Is my UK pension taxed in the United Kingdom or in France?

Private pensions are generally taxable in France for a French tax resident. Government-service pensions follow a separate treaty rule, including an exception linked to nationality. Establish which provision covers each scheme; the country of the bank account receiving the money does not decide the answer.

Can I still take my 25 percent tax-free lump sum after moving to France?

The provider may be able to pay a UK tax-free amount under its rules. Its French treatment requires a separate treaty and domestic-law analysis. Ask for the details of the proposed payment before instructing it, including whether further benefits remain in the scheme.

Is a QROPS transfer worth doing if I live in France?

Compare it with keeping the existing scheme. The review should cover guarantees, fees, investment options, the overseas transfer charge and future residence plans. Check the receiving scheme and the advice requirements for the benefits involved.

Can I keep paying into my SIPP after moving to France?

Three answers are needed. Keeping the SIPP depends on the scheme rules and the provider’s terms for clients resident in France; accepting new contributions is the provider’s decision; UK tax relief on them is a legal right only for contributions paid before your 75th birthday and only while you are a “relevant UK individual”, that is, with UK earnings taxed in the UK in the tax year, or in the five UK tax years (6 April to 5 April) following the one in which you were last UK resident, if you were UK resident when you joined. Relief is limited to your UK earnings or, if they are lower or nil, to £3,600 gross a year; relief on that basic amount, beyond your UK earnings, can only be given through relief at source, by a scheme that operates it (Finance Act 2004, sections 188 to 192), and whether the contribution also reduces your French tax depends on French rules, not on the UK relief.

Do I have to declare my SIPP on my French tax return?

Examine the SIPP’s legal form and documents to determine which French disclosures apply. Reporting an account or policy can be required without a withdrawal. The declaration of benefits received is a separate question.

What happens to my UK state pension when I live in France?

It continues to be paid, it cannot be transferred to any other scheme, and it is not affected by anything you do with your private pots. Its annual increase depends on the arrangements between the United Kingdom and the country where you live rather than on your contribution record, so the same entitlement can behave differently depending on where you settle. It is worth confirming your record with the UK authorities before assuming the amount, particularly after a career split between countries.

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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