The UK government gives citizens a great deal of flexibility in selecting a pension plan that best suits their circumstances. This level of flexibility allows clients to choose from a variety of regulated pension plans, such as money purchase, final salary, defined contribution, QROPS, SIPP, International SIPP, and QNUPS.
**We ran a deep dig on QROPS USA here.
Many people in the United Kingdom still hold a final salary pension plan. After reaching the age of 55 or the date of retirement, the provider will guarantee a set level of income. Although, in recent years, people have been given the option of exchanging their last salary pension for a variety of appealing pension options.
A final salary pension transfer is a decision to exchange the benefit of a defined benefit (DB) pension for cash value and transfer it to another preferred pension scheme. The transfer gives you more control over the pension pot. Some people want to manage their pension scheme in order to try and achieve higher benefits than the current DB pension.
A major benefit of a private or personal pension plan is greater control over your pension plan. You have control over your pension pot and can manage it regardless of where you live.
Some employees in the United Kingdom may have switched from a defined benefit pension plan (DB) to a defined contribution pension plan (DC). However, many individuals may be unhappy with their present investment or their previous financial advisor. Another reason is that they are planning to relocate to another country and need to set up an international pension plan because they will be leaving the UK and retiring elsewhere.
Transfer defined benefits to SIPP
If you consider transferring your Defined Benefit (DB) pension scheme to an International SIPP, first, the trustee will convert the benefit you have into a cash sum also called a CETV (Cash Equivalent Transfer Value). Cash equivalent transfer value is a term in accordance with the pension calculator on how and how much the pension will be paid.
Commonly, there are two main ways the trustee calculates your CETV: A method based on the best estimate of the expected cost of providing the member's benefits in the scheme; and an alternative method for trustees who want to pay CETVs in excess of the minimum amount; a framework for calculating an initial cash equivalent is the best-estimated method. The legislation establishes a framework that allows for the calculation of an "initial cash equivalent" (ICE), which is then adjusted if necessary to arrive at the final CETV available for transfer by the member.
The next step is that your trustee will exchange this cash sum into a self invested pension scheme or SIPP. Find out more about CETV in our in-depth analysis.
Is QROPS Suited for US Residents?
Non-UK residents can transfer their pension plans to a Qualifying Recognized Overseas Pension Scheme (QROPS) or an International Self-Invested Personal Pension (iSIPP). However, a QROPS scheme is subject to a 25% tax on transfers for non-EEA residents.
There is a small number of circumstances in which this 25% Overseas Transfer Charge is not applicable. A client who resides in a country who could utilise a locally regulated QROP in the country of residence, can transfer without paying the 25% OTC charge. Find out more about the Overseas Transfer Charges here.
QROPS is frequently offered to non-UK citizens as a means to reduce their tax responsibilities in the United Kingdom. However, the facts show that QROPS is not a feasible alternative for US residents for two reasons: the IRS does not recognize QROPS as an option, and the HMRC does not enable UK employees to transfer their pension to the US through QROPS USA.
The Self-Invested Personal Pension (SIPP) is a viable solution for the UK’s employees considering their pension transfer option in the US. As the IRS stated:
“If an employer pension scheme in the United Kingdom and a SIPP are both pension schemes within the meaning of Article 3(1)(o), then a transfer of income earned by the employer pension scheme to the SIPP would not be a taxable event in the United States.”
You need to seek advice from trusted and registered financial advisors to help you manage your investment in the best manner possible.
What is a SIPP Pension UK?
A Self Invested Personal Pension Plan is a tax-advantaged investment designed to consolidate your UK pension schemes from wherever you reside to access greater flexibility and control over your pension funds before and during retirement. Tax- advantaged investment, sounds technical right? Tax-advantaged investment simply means a reduction in taxes approved by Her Majesty Revenue and Customs (HMRC). An International SIPP is the most tax-efficient tool for consolidating your UK pensions as a US-Resident.
UK SIPP For US Citizen - International Self Invested Pension Plan (ISIPP)
International SIPPs are one of the possible alternative personal retirement plan options if you plan to migrate to the United States or if you already live there and want to combine your UK pension plan while living in the United States.
The Self Invested Personal Pension (SIPP) and the International Self Invested Personal Pension (iSIPPs) are two types of self-invested personal pensions recognized by HMRC. The structure of both schemes is exactly the same in that they are both HMRC-regulated plans, but their purposes may differ.
SIPPs are designed for UK residents and the International SIPP for Non-UK Residents including the USA (US Residents or US Connected Persons). Allowing you to effectively manage your UK retirement plan by maintaining the assets in the UK but managing them from overseas as a non-UK resident. Cameron James will assist you in gaining a thorough understanding of the International SIPP.
UK Pension in USA
The most significant issue with administering your current UK pension plan while living in the US is that the DB or DC UK pension plan is only intended for use by UK residents. If you have been out of the UK for more than five years, you may encounter a number of things to carefully consider in the transfer of funds.
Along with the aforementioned concerns, tax is one of the most common issues you may encounter while administering your current UK pension plan in the US. According to the Foreign Account Tax Compliance Act, you will be exposed to increased tax or penalty tax while filing your UK or US tax return (FATCA).
Fortunately, International SIPPs are designed to facilitate non-UK residents, including US residents, to manage their pension investments in the US without having to deal with the residency and tax deduction issues associated with the FATCA issue.
International SIPPs are a possible alternative if you plan to migrate to the United States or if you already live there and want to consolidate your UK pension plans..
You can hold dual UK and USA citizenship to an international SIPP. When you live in the United States, you can still draw down on UK pensions to the US without incurring any tax consequences. According to the SIPP UK US tax treaty, any payment of UK retirement benefits to US residents is solely subject to US taxation. Cameron James will assist you in gaining a thorough understanding of the International SIPP.
Is the UK 25% Pension Commencement Lump Sum tax-free in the USA?
Despite numerous IFAs in the USA telling clients that their UK 25% PCLS is tax-free in the US, there is a large raft of information that is contrary to this. While it would be easier to tell clients that it is tax-free as this will likely increase the eagerness to complete a transfer with Cameron James, we prefer to be transparent. However, different regulations may apply in the United States. Your 25% lump sum will be taxed in the United States. In the United States, the term "Lump Sum" refers to a complete withdrawal; therefore there is no law for a 25 percent PCLS.
UK Pension Eligibility
Can a non-UK resident open a SIPP?
SIPPs or Self Administered Pension Plan Schemes are offered for people who live in the United Kingdom and are governed by the UK pension eligibility regulations. As a result, getting a UK pension through a UK SIPP is not available for US citizen receiving UK pension. For non-UK residents who want to consolidate their UK pension scheme overseas, the International SIPP is the ideal alternative supported by the UK pensions rules.
Can US residents open a SIPP in the UK?
Due to FCA restrictions, US residents are unable to open individual pension plan in the UK. Except for International SIPPs, HMRC does not recognize transfers from another country to any UK pension system. International SIPPs are created for people who reside overseas including in the USA.
Can I transfer a SIPP to the US?
It is not possible for a US Expat with UK SIPP to transfer abroad this SIPP or any of their UK pensions (Final Salary, Defined Benefit, Defined Contribution or SIPP) to the US or a US pension product like a 401k. To clarify again, UK employees who live in the US cannot consolidate their pension and transfer UK pension to 401k or any US equivalent scheme. We have had many clients ask this question about UK pension to 401k transfers.
While we agree that it would be ideal, the US and UK government does not allow pensions to be consolidated or mixed for obvious tax reasons. As such, your UK pension assets cannot be transferred and held on the typical US platforms (TD Ameritrade, Interactive Brokers, Charles Schwab, and so on), they do not accept UK pension assets.
The Internal Revenue Service (IRS) of the United States does not permit tax-free transfers from foreign pension plans to their domestic equivalent. As a result, transferring the UK's pension scheme is not possible for UK expats living in the US. Find out more about IRA and 401(k) retirement plans in our in-depth analysis.
Benefits of an International SIPP
International SIPPs give you the freedom to choose and manage your own investments. Although it has some similarities to defined contribution pension schemes, International SIPPs provide the client with greater flexibility and a tax-efficient way to save for retirement.
SIPPs were first introduced in the UK Parliament's 1989 Budget, according to the UK Parliament. The Financial Conduct Authority (FCA) in the United Kingdom regulates SIPPs to encourage employees in the United Kingdom to save for retirement. International SIPPs, unlike other UK retirement plans, allow individuals to invest in a wide range of investments while gaining tax benefits from wherever you reside
2. Currency flexibility
There are numerous key features of International SIPPs that provide you with options such as a full range of investment options, including the ability to invest in a variety of currencies including the big three of USD, GBP, and EUR. This currency flexibility allows US-resident clients to hold some or all of their UK pension assets in USD which is their currency of retirement.
This allows you to reduce or eliminate currency risk, in this case if GBP were to decline in value against USD just before your retirement. For example, a number of our clients working in New York, often keep an equal split (50% / 50%) of USD and GBP providing them with greater freedom for their future withdrawals or expenses they may incur. Learn more about Currency Options within an International SIPP.
3. Wider Range Of Investments
Typically, the standard UK retirement benefits offer a limited pre-packaged range of fund options. Not only are UK pension plans often limited, they are also often expensive and provide poor value for money.
For example, a UK pension scheme may create an in-house XYZ Balanced Fund for you to purchase for 0.5%-1% pa (per annum). While this may not sound expensive, particularly with equities markets often achieving 5-10% growth pa, the reality is that this in-house fund is made up of a range of underlying funds from companies such as iShares, Vanguard, and BlackRock, which can cost as little as 0.07% pa. As such, UK pension funds are often charging clients twice without realising as they are marking up the price of these funds which they sell onto you.
This is unlike an International SIPP with Cameron James where we provide you with direct access to those very same funds, but without the huge mark-up. We feel this is the fairest and most transparent way to create our clients’ portfolios.
International SIPPs offers a wide range of investment including stock exchange-listed investment trusts, commercial property, gilts and bonds, stocks and shares, investment trusts, Financial Conduct Authority-recognised Open-Ended Investment Companies (OEICs), bank deposit account, exchange-traded funds (ETFs), and real estate investment trusts.
The reality though, is that very few clients will utilise this full range of asset classes. We will typically advise our clients to hold a combination of both passive and active funds. Passive or tracker funds are effectively low-cost funds (commonly referred to as ETFs) which simply track the market and can provide great long-term returns with minimal costs. While active funds try to outperform the market for higher returns. We only advise active funds which are low cost and have a long-term track record of achieving alpha and outperforming the market.
To learn more about this, please read our dedicated articles explaining Passive Funds and Active Funds and why we use a combination of both at Cameron James inside your International SIPP.
4. Transferring Shares into SIPP
When our clients transfer shares into an international SIPP scheme, a different approach will be taken. The transfers are categorized as ‘in-specie' transfers.
Transferring ownership of an asset in-specie is defined as doing so without first converting it into cash. An in-specie SIPPs transfer may be advantageous if the client wishes to avoid being out of the market on a specific asset; however, the transfer is uncommon in the United Kingdom.
If you are considering transferring UK shares into your SIPP, this is something we can help you with. Unfortunately, the transfer of US-listed shares into your SIPP is not possible at this point.
5. Cost Efficiency
Each of your UK pension schemes will have its own set of fees and charges. These may be fixed administration charges or percentage-based charges. Our clients can eliminate duplicate these costs and achieve lower annual expenses by transferring and consolidating their UK DB (Final Salary) or DC pensions into SIPPs. Allowing you to benefit from a greater fund value in retirement.
Additionally, many UK pensions schemes, particularly older employee-based DC plans, can have high fees or even bid-offer spreads (1-4%) on the purchase of the underlying funds. At Cameron James, we have a 0% bid-offer spread on all assets we buy for our clients.
6. Early Withdrawal
You have control over when and how much you withdraw from your pension pot once you reach the age of 55. On paper, the client can withdraw the entire pension pot in their first year of retirement; however, there are some risks involved. The client may have to live the rest of their retirement with insufficient funds. The first 25% will be admitted as a tax-free lump sum and the remaining 75% will be considered as income and taxed at the marginal rate in the US or your country of residence at that point.
Pension providers will not allow you to withdraw funds before the age of 55. If you withdraw your funds before the age limit, you will be charged a hefty fine. The HMRC will levy a 55% tax on UK SIPP distribution before age 55, you may be subjected to exit penalty charges.
Kindly note from 2028, it is the Government's intention for this normal retirement age to rise from 55 to 57. As such, if you are currently in your early 50’s, this is a key area that you need to understand.
You can learn more about this in our dedicated page - Normal Retirement Age To Rise from 55 to 57.
7. Pension Commencement Lump Sum
Pension commencement lump sum (PCLS) is a tax-free payment you can receive when you begin receiving benefits from your UK pension retirement funds. The UK government allows you to take a tax-free lump sum of 25% of your pension fund.
And the remaining 75% of the fund will be treated as taxable. You still can decide how to draw their fund; as lump-sum, multiple lump sums, or and an annuity. The policy is valid anywhere, regardless of where you live.
However, withdrawals of funds will be subject to the laws of the country in which you reside. If you reside in the United States, you will not be taxed twice on your withdrawal. You will only be taxed in the United States.
However, as mentioned previously, it is not wise to assume that the 25% PCLS will also be tax-free in the US. Kindly see Is the UK 25% Pension Commencement Lump Sum tax- free in the USA?
8. FCA Protection
Your International SIPP is fully FCA regulated and protected by the UK government, regardless of where you live. This policy is critical for expats who no longer reside in the UK or live in less-regulated countries, but still want to be protected by the FCA.
9. Death Benefits
You can also access death benefits through an International SIPP. Death benefits are usually exempt from Inheritance Tax in the United Kingdom and the United States; however, different rules may apply in some cases. The benefit can also be passed down to designated death beneficiaries.
In the event of the death before the age of 75, the whole of your SIPP benefit will be paid out as a lump sum or as an income stream without any UK tax on the benefits paid to beneficiaries. On the contrary, in the event of death after the age of 75, the beneficiary will pay the UK income tax on any benefits they receive.
The goal of this legislation from the UK is to stop people from putting all their assets into a SIPP and passing onto their beneficiaries tax-free, which is fair enough.
Taxation of International SIPPs
Is transfer from UK pension to SIPP taxable event?
The UK pension system is taxed on an EET (Exempt, Exempt Taxed) basis. The contribution paid to the pension fund is tax-free, as is the growth of the investment made within the pension fund. In addition, the pension fund benefit will be considered taxable income. The system functions similarly to the 401k system in the United States.
The term 401(k) is derived directly from the section of the tax code that established this type of retirement plan. According to 401(k), the retirement pot is not taxable until the employee receives the benefit of the pension fund, at which point their income is typically lower than it was during their working years.
Meanwhile, Australia has a distinctive system of taxation of retirement funds. The superannuation system works on Taxed, Taxed, Exempt (TTE) basis. The contribution to the retirement pot is considered taxable, the growth of investment is also considered taxable, and the benefits paid from pension funds are considered tax-free.
Do dual citizens pay taxes in both countries?
In theory, the Internal Revenue Service (IRS) does not recognize foreign pensions as qualified plans in the US. As a result, any contributions made by non-UK residents in the US to UK pension schemes will not be tax-deductible in the US, and any contributions made by the employer will only increase their taxable income.
If the UK pension scheme invests in foreign Exchange-Traded Fund (ETFs) or mutual funds, it may be classified as a passive investment company and subject to tax. As a result, any benefits from their funds are taxed by both the UK government and the IRS, though clients may be able to claim to FTC (Federal Trade Commission) to take advantage of tax treaties to avoid double taxation. For the US resident, International SIPP is the best option available on the market.
How to claim report UK SIPP on US tax return?
You must officially notify HMRC and the pension provider that you have already resided in the US or overseas in order to access your pension fund without any tax deduction in the UK. Otherwise, you may face taxation or withdrawal complications. Find out more details relating to your US tax return.
How to claim tax SIPP from UK tax return?
If you are a US resident and wish to take advantage of the extra tax reduction on your International SIPP payments, you must do so through self-assessment tax returns. Completing the procedure of self-assessment tax returns can be difficult; thus, it is important to prepare important details such as:
1 10 Digit of your Unique Taxpayer Reference (UTR)
2 National Insurance number
3 Details of any expenses relating to your self-employment
4 Details of any contribution to your SIPP that might be eligible for tax relief
5 P60 form
What is inheritance tax?
Inheritance tax is a tax that a beneficiary must pay on the estates they inherit, including property, funds, and possessions, in the event of the decedent's death. In the UK, when an estate exceeds £325,000 (£650,000 for a married couple), the standard Inheritance Tax (IHT) rate of 40%. Inheritance Tax (IHT) is taxed on both UK or US residents.
There is a significant distinction between being a UK resident and being a UK ‘domiciled' person. Unless you have citizenship, you may be a UK domiciled person if you were born in the UK, one or both of your parents were born in the UK, or you were raised in the UK.
This could have implications for the estates of people who retire and leave the UK, and it will be critical for the beneficiaries. Many of our clients tell us they have not been in the UK for many years and have no IHT obligations in the UK, this is often not the case and this is a really technical area.
It is critical to seek advice from a reputable financial advisor. You can learn more here to fully understand your IHT obligations for UK and US related to UK pension.
Potential disadvantages of International SIPP
Transferring DB (Final Salary) pensions into an International SIPP has both potential benefits and risks. International SIPPs provide you with greater flexibility in managing investment risk, more control over your pension investment, and the potential for lower management costs when compared to other UK pensions.
On the other hand, transferring a DB pension into an International SIPP, carries additional risks, including increased investment risks, and the loss of existing pension scheme benefits.
1. Administration issues
The most significant issue that may arise when deciding on an International SIPPs is the administration. After working in the UK your UK pensions may be fragmented, in the fact that they are held with numerous providers.
UK pension schemes are often understaffed and extremely inefficient at processing requests. Simply requests for information can take up 10-20 working days and we have even seen 45 working days during the CV19 pandemic.
As such, you will need to remain patient and our advice to allow us to complete as much of the administration for you as possible as that is what you are paying us to do, and we deal with these companies every day, so we are experienced in working with them.
Along with administrative complications, currency depreciation will be a more difficult issue for those who plan to use international SIPPs as a pension scheme. Expats frequently have a number of Sterling investments in SIPPs. The risk will arise when the pound is under pressure.
The best protection against this is hold some of all of your SIPP in your currency of retirement. Learn more about Currency Options within an International SIPP.
3. Potential loss of existing benefits
If you have no other backup options for achieving your retirement goal, a transfer of your DB pension may not be appropriate for you. The transfer is best for you if you do not rely solely on DB schemes for your income and have other sources of income, pension, and investment.
Once the transfer is taken, you cannot return to the UK DB scheme. If you decide to transfer into SIPPs, your existing safeguard benefits will be lost. Previous DB or DC scheme benefits may be more valuable in some cases than international SIPPs.
Scams can begin with an unwelcome phone call from fraudsters. It is essential to only accept calls from your trusted advisor. Keep an eye out for any calls that may arrive before or after transfers. You may become a victim of a scam as a result of the transfer. Fraudsters are becoming increasingly smart and finding new ways to access people’s hard-earned money and pension pots. According to the FCA, nearly hundreds of millions of pounds have been defrauded from unsuspecting pension holders.
You should pay close attention to unregulated, alternative, and esoteric investment opportunities. Such an investment is at the heart of all investment frauds. It is extremely crucial to only invest in regulated investments that will protect you from scams. Check the adviser's credentials, track record, and experience. Only a qualified and trustworthy adviser should provide pension advice.
To avoid risks and losses, International SIPPs require you to be an experienced investor or at the very least have proven knowledge and experience in investment. Otherwise, you should seek advice from a reputable and registered financial advisor to help you manage your investment as effectively as possible. Find out more about how to find a qualified financial advisor in our in-depth analysis.
The value of your investment may rise and fall in proportion to the growth of the investment product you buy. As a result, you may receive less than you invested. Prior to making a decision, it is critical to pay close attention to investment selection and to regularly monitor performance.
How to transfer into International SIPPs?
A pension transfer requires you to submit a written legal application to the scheme administrator and pension provider, requesting any necessary details and informing the regulator and pension provider of your decision to transfer from one scheme to another.
If you are a member of a DB pension and the fund exceeds £30,000, the FCA requires you to seek professional FCA advice which we provide at Cameron James.
Before making any decisions, the FCA recommends that you seek professional advice from a qualified financial adviser. Cameron James will assist you in reducing your financial risks and making the best decision for your retirement.
If your condition meets the requirements, you may transfer your pension scheme:
You are a member of a defined benefit plan in the private sector.
You are enrolled in a government-funded public-sector program.
A transfer from a DB pension is frequently not possible if you are enrolled in NHS or other public sector plans.
Whether transferring a DB pension scheme and a DC pension scheme into the international SIPPs, you will complete the advice process with a qualified financial adviser who will recommend the most suitable International SIPP solution and portfolio allocation. The transfer requires the FCA sign-off if the DB transfer value exceeds £30,000.
The International SIPP transfer process is transparent. We will analyse your profile and your adviser will then provide a clear and comprehensive understanding of your current situation and the investments that are most suitable for your needs.
The adviser will complete a Letter of Authority with you during the consultation. This document gives the adviser the authority to officially notify their pension provider via mail or email to gather the relevant information (e.g., transfer value, cost, charge, etc). The LOA, however, does not grant the adviser the authority to transfer the pension.
Following the selection of the appropriate International SIPPs option, we will complete your transfer paperwork, and our ongoing service and reviews will commence. Transferring into SIPPs allows you to access and review all of your investments online 24 hours a day, seven days a week. Your financial adviser will provide an accurate projection of their pension income at retirement.
Best International SIPP
When it comes to charges, transferring into an overseas SIPP program is all about keeping your costs as low as possible. The Financial Times highlighted the fees to consider when transferring to an International SIPP, and this may be a factor in your decision to choose a low-cost SIPP provider UK. Please keep in mind that the prices may vary depending on the company's updates.
|Annual costs||SIPP closure fee||Exit charges to UK scheme||Exit charges to overseas scheme|
|My Expat SIPP||Any amount||£150||£0||£75||£75|
|Novia global International SIPP||Any amount||£180||£0||£0||£0|
|Pensions platform SIPP||Any amount||£200||£0||£500||£1,000|
|PSG harbour International SIPP||Any amount||£399||£499||£180||£360|
|Forthplus SIPP||Any amount||£400||£0||£0||£0|
|Sovereign International SIPP||Any amount||£500||£0||£250||£400|
|iPensions adviser SIPP||Under £1m||£500||£0||£500||£1,000|
|iPensions USA SIPP||Under £1m||£500||£0||£500||£1,000|
|STM Pension Plan (Fixed Rate)||Any amount||£500||£860||£155||£350|
|iPensions Adviser SIPP||£1m to £1.5m||£1,000||£0||£500||£1,000|
|iPensions Adviser SIPP||£1m to £1.5m||£1,500||£0||£500||£1,000|
|iPensions USA SIPP||£1m to £1.5m||£1,500||£0||£500||£1,000|
*These fees are excluding VAT if applicable.
Why choose Cameron James?
Cameron James is the preferred independent financial advisor for International SIPP transfers. With over 10 years of experience in transferring pensions, Cameron James is now servicing clients in 23 countries.
We have the qualifications and technical knowledge required to help you transfer to international SIPP both as an expat and US resident. Our mission is to bring regulated and transparent advice to our clients. Our clients fully know how much their advice will cost in advance with no hidden fees.
CJ has a sophisticated cash flow management system in place. Our senior management team has a decade of expertise serving expats and is committed to continuing to serve the requirements of expats for decades to come.
Transferring a DB or DC pension into an International SIPP plan for expats is not a simple decision. Before making a decision, many details and procedures must be thoroughly understood. Without comprehension, the benefit will turn into a potential loss. Find out more about the international SIPP example.
It is essential to seek a set of competent advice from a qualified financial advisor to verify that your profile matches the suitable options and to ensure that your option meets the UK and US regulations. Meet our dedicated adviser to find out a comprehensive understanding of International SIPP.
There is no one size fits all answer
Our job would be easier if there were a one size fits all solution. It will depend on your situation and requirements. Everyone's needs are different. For example, what may be the best advice for your colleague of a similar age may not be the best advice for you. Where you live, where you plan to retire, the value of your pensions and your attitude to risk are all determining factors.
Your pension pots are likely your most significant asset after your house, so taking advice from an experienced professional who specializes in this area is wise. Seeking qualified advice from an Independent Financial Adviser (IFA) is always the best course of action. Our IFA's look forward to working with you and helping you find the best International SIPP for your requirements.