By Jonathan Laws, ACA, Ch.FCSI, Senior Independent Financial Adviser, Cameron James USA
If you are an expat holding a UK pension, the platform your adviser recommends for the receiving SIPP matters as much as the transfer decision itself. Novia Global and Morningstar Wealth International are the two International SIPP platforms Cameron James uses most often, and both are built to be used through a suitably authorized adviser rather than on a self-directed basis.
This article compares how the two handle account access, custody, provider charges and investment choice. If you are a US citizen or US taxpayer, the comparison changes materially rather than marginally, because one platform can support US-domiciled funds and a general investment account for a US person and the other cannot. That section is below and, for most readers of this site, it is the one that decides the answer.
Which platform is right for your pension?
It depends on the value being transferred, your drawdown pattern and whether you are a US person. Book a free consultation and we will model both on your actual numbers before recommending either.
Key Takeaways
- Both are International SIPPs used to receive UK pension transfers from expats, and both are adviser-only. Neither is available on an execution-only, self-directed basis.
- Both use an independent Channel Islands custodian: Novia Global with BNY Mellon Pershing, Morningstar with Northern Trust. You remain the beneficial owner throughout.
- On the annual platform charge alone, Novia Global is marginally cheaper at £250k. Morningstar is cheaper by £750k and the gap widens above that, because its tiers step down sooner and further.
- Scheme and dealing charges are structured differently and can move the total in either direction, so the headline percentage is not the answer on its own.
- For a US person the comparison is not close on two points. The Novia Global general investment account is not available to you as a standalone wrapper, and Novia Global does not accept US-domiciled funds at all.
- Morningstar runs a dedicated service tier for US taxpayers that supports US-domiciled funds, which sidesteps the PFIC question outside the pension rather than relying on a wrapper-level exception.
- PFIC reporting does not apply to fund holdings inside either SIPP during accumulation. The platform choice does not change that. It changes what happens outside the pension.
Can Expats and Other Non-UK Residents Use Either Platform?
Both providers are International SIPP platforms built for expats and other non-UK residents, and both are distributed on an adviser-only basis rather than direct to consumer. Neither allows you to open an account and trade it yourself. Access is provisioned to the adviser firm, and your adviser needs to hold the appropriate authorization for your country of residence before advising you on either platform. For a US resident that means individual SEC authorization.
Both are UK-regulated SIPP structures, which matters beyond distribution rules. A SIPP is a well-established, tax-efficient home for a UK pension once you leave the UK, offering multi-currency facilities, flexible drawdown, and access to a range of collective funds that a domestic UK platform may not extend to a non-UK resident. The choice between the two comes down to account structure, custody, cost and investment access.
How Are Assets Held? Custody and Safekeeping
Neither platform holds your investments directly in your own name. Both operate through a custodian and nominee structure, which is standard for adviser platforms of this kind and does not affect your beneficial ownership of the underlying assets. You remain the beneficial owner throughout.
On Novia Global, client assets are held with BNY Mellon Pershing Channel Islands. Custody of fund holdings is charged separately from the main annual service charge, at 0.04% a year on the value of fund holdings excluding cash, and that is folded into the tiered figures in the fee tables below for a like-for-like comparison. Direct equities, bonds and exchange traded funds carry their own custodian settlement charge on top, shown in the dealing charges table.
On Morningstar Wealth International, client assets are held with Northern Trust Channel Islands. The published charge is a single all-in custody and administration percentage rather than a separately broken-out custody line. The SIPP itself is operated by Morningstar Wealth Retirement Services Limited as trustee, with Morningstar Wealth International Limited providing the platform and Northern Trust providing the underlying custody.
In practice both structures mean your pension assets sit with a globally recognized independent custodian in the Channel Islands rather than with Cameron James or with you directly. Cameron James, as your adviser, directs how those assets are invested but does not hold or safeguard them. Because the cost of custody is built into the percentage charges compared below rather than shown as a separate decision, it is a factor in the fee comparison rather than a separate choice you need to make.
Account Types and Structure
For most clients the International SIPP is the product actually used on both platforms, since it is the wrapper that receives a UK pension transfer. Novia Global also operates a Global Investment Account and a Stocks and Shares ISA alongside its SIPP, giving a broader range of wrapper types on a single platform for clients who want to hold other savings alongside their pension. Morningstar is used by Cameron James for the International SIPP in the great majority of cases.
Both are administered on an adviser-facing rather than a retail-facing basis, and withdrawals from either are processed in sterling only, which is a practical currency planning point if you draw income in another currency. If you are a US person, the position on the Novia Global general investment account is different and is covered in the dedicated section below.
Adviser-Only Access, and Why Self-Investing Is Not an Option
Both are advised platforms. Access is provisioned to the adviser firm, dealing instructions are placed by the adviser under an advisory or discretionary mandate, and neither set of terms permits a client to log in and trade independently. We cover this in detail for one platform in our article on whether you can self-invest a Novia Global SIPP.
Cameron James does not facilitate a self-invested, execution-only approach on either platform. This is not a preference. It reflects the basis on which the accounts are opened and regulated: an execution-only client relationship is a different regulated activity from advised investment management, and running one inside an advised SIPP wrapper is not something the platform terms, or the regulatory permissions our advisers hold, support. If genuinely self-directed investing is what you want, an advised International SIPP is the wrong product, whichever provider you choose.
Fees Compared
These are the published scheme, platform and dealing charges of the two providers, taken from the current fee schedules available to Cameron James. They are not Cameron James advice fees. They are set out in full because the structure of each set of charges, not just the headline percentage, affects which platform suits a given pension value, investment approach and drawdown pattern.
SIPP scheme charges
Both providers itemize scheme-level charges by event rather than charging a single all-in fee. Which structure costs less depends on how many crystallization and drawdown events you expect over the life of the pension, not just the headline annual figure.
| SIPP scheme charge | Novia Global International SIPP | Morningstar International SIPP |
| Establishment fee | None | £195 one-off |
| Annual SIPP service or administration charge | £240 a year, being £60 per quarter paid in advance | £195 a year, charged in advance |
| Benefit crystallization charge | £200 per crystallization event | None |
| Income drawdown charge | £150 a year | £125 a year |
| Overseas pension transfer-in charge | £250 per transfer | Not separately itemized in the published schedule |
| Ad hoc or time-costed administration | £100 per hour | £100 per hour |
Table: scheme-level charges as published at the review date.
Annual platform and custody charge
This is the charge that pays for safekeeping your assets with the custodian of the platform, in addition to general platform administration. The Novia Global annual service charge tiers down from 0.30% to 0.10% as account size rises, and the table below adds its separate 0.04% custody charge to each tier for a like-for-like comparison with the all-in Morningstar figure, which tiers down from 0.35% to 0.03% across six bands rather than four. Novia Global tiers are set in US dollars, so an account held in another currency has its tier determined by the prevailing exchange rate at the time.
| Tier | Novia Global, service charge plus 0.04% fund custody | Morningstar, all-in custody and administration |
| Entry tier | 0.34% up to $500k | 0.35% up to £250k, $350k or €300k |
| Second tier | 0.29% on $500k to $1m | 0.28% on £250k to £500k |
| Third tier | 0.19% on $1m to $2m | 0.21% on £500k to £1m |
| Fourth tier | 0.14% above $2m | 0.14% on £1m to £2m |
| Fifth tier | Not applicable, flat 0.14% above $2m | 0.07% on £2m to £5m |
| Top tier | Not applicable, flat 0.14% above $2m | 0.03% above £5m |
Table: tiered annual charges as published at the review date.
Worked examples by account size
The figures below apply the tiered rates above to five illustrative account sizes, converting the Novia Global dollar tiers to sterling at an indicative rate of $1.30 to the pound. This is for illustration only. The actual Novia Global charge on a given day depends on the prevailing exchange rate, and neither figure includes scheme charges, dealing charges or advice fees.
| Account size | Novia Global annual platform charge | Morningstar annual platform charge |
| £250k | About £850 a year, around 0.34 percent | £875 a year, 0.35 percent |
| £750k | About £2,367 a year, around 0.32 percent | £2,100 a year, around 0.28 percent |
| £1.5m | About £3,812 a year, around 0.25 percent | £3,325 a year, around 0.22 percent |
| £2.5m | About £5,231 a year, around 0.21 percent | £4,375 a year, 0.18 percent |
| £5m | About £8,731 a year, around 0.17 percent | £6,125 a year, 0.12 percent |
Table: illustrative only, at an assumed exchange rate of $1.30 to the pound. Not a quote.
At £250k the Novia Global platform charge comes out slightly lower. By £750k Morningstar is the cheaper of the two, and the gap widens at £1.5m, £2.5m and £5m, because the Morningstar bands step down sooner and further. That is the platform charge only. Scheme charges and dealing charges can move the total in either direction, which is why a full comparison should be run on your actual pension value and investment approach rather than on the platform charge alone.
Dealing and transaction charges
This is where the two differ most in structure. Novia Global charges per trade for fund dealing, varying by the domicile of the fund, plus a separate stockbroker commission for direct equities, bonds and exchange traded funds. Morningstar charges a flat, currency-denominated fee per trade that is materially higher for equities, bonds and exchange traded funds than for managed funds. An investment approach built around frequent direct dealing or rebalancing will cost meaningfully different amounts on the two platforms, independent of the annual percentage charge.
| Dealing or transaction charge | Novia Global | Morningstar Wealth International |
| Fund dealing charge | $5 per trade for a UK, Luxembourg or Irish domiciled fund, $10 for Channel Islands domiciled, $175 for non-standard instructions | £4.00, $6.00 or €5.00 per trade for managed funds |
| Equity, bond and exchange traded fund dealing | $2 per exchange traded fund trade, plus stockbroker commission of 0.05% UK, 0.08% international and 0.1% Australian, each subject to a minimum per trade | £8.90, $11.90 or €10.90 per trade |
| US taxpayer reporting fee | No equivalent identified in the published schedule | £195, $200 or €200 a year, levied for US investors |
| Bank transfer charges | Foreign exchange charge of 0.20 percent, payment-out charge of $17.50 | BACS free, CHAPS £30, $45 or €40, Faster Payment £10 |
Table: charge schedules on both platforms are published by the providers and are subject to change. These figures reflect the most recently published schedules at the review date and should be checked against the current version before any decision.
For US Persons: Where the Comparison Stops Being Close
Everything above applies to expat and other non-UK resident clients generally. If you are a US citizen or US taxpayer, three related points change the answer, and on two of them the platforms are not comparable rather than merely different. Cameron James advisers hold individual SEC authorization and can advise US-connected clients on either platform, so this is a product question rather than a permissions one.
General investment account access
The Novia Global general investment account is not available to you as a standalone wrapper if you are a US person, so the broader wrapper range described earlier is largely academic and you are limited to the SIPP on that platform. Morningstar Wealth International runs a dedicated service tier for US taxpayers that extends beyond the SIPP, supporting a general investment account, an ISA and certain international pension structures, subject to important limitations on each.
PFIC
A SIPP itself is not a PFIC, and fund holdings inside it fall within a reporting exception during accumulation, under the treaty and the regulations at section 1298(f), readable in the Code of Federal Regulations. That applies whether the SIPP sits on Novia Global or Morningstar, so the platform choice does not affect your PFIC position for pension assets. It does not extend to holdings outside a pension wrapper, such as a general investment account, and that is where the difference bites.
This is where the US-domiciled fund access on Morningstar is a structural advantage rather than a preference. A US-domiciled exchange traded fund is not a PFIC at all, because PFIC status only ever attaches to non-US funds. A US person buying one through the Morningstar service tier sidesteps the question entirely for that holding, rather than relying on a wrapper-level exception to manage it, and avoids the per-fund, per-year reporting on Form 8621 that a non-US fund held outside a pension would create. Novia Global does not accept US-domiciled funds onto its platform at all, so US equity exposure held there, whether inside the SIPP or otherwise, is always held through a UK or Ireland domiciled fund. Our guide to PFIC restrictions for US-connected investors covers the wider problem.
Withholding tax on US dividends
A UK or EU domiciled fund, such as an Ireland-domiciled UCITS exchange traded fund tracking US equities, is itself a non-US person for US tax purposes. When that fund receives dividends from the US companies it holds, US withholding tax is deducted at fund level, commonly at a 15% treaty rate under a Form W-8BEN-E position, before the income reaches the investor. That drag sits inside the performance of the fund and cannot be reclaimed by the underlying investor. A US-domiciled fund does not carry the same structural layer, because it is a US taxpayer receiving US-source income directly.
Two points of precision. US withholding tax applies to US-source dividends and income, not to capital gains. And this is our professional understanding of how PFIC and withholding rules interact with fund domicile, not individual tax advice: the position can vary by holding, by treaty and by tax year, so anyone weighing it up should discuss their own facts with a cross-border tax adviser.
The short version for a US person
If a general investment account, PFIC-clean investing beyond the pension wrapper, or withholding tax efficiency on US equity income are priorities for you, Morningstar Wealth International through its US taxpayer service tier is the platform that can deliver them and Novia Global cannot, regardless of investment strategy. If none of those is a priority, the Novia Global SIPP remains a workable choice, provided US equity exposure is planned around its UK and Ireland domiciled fund range.
Side by Side
| Feature | Novia Global | Morningstar Wealth International |
| Distribution model | Adviser only. Not available direct to consumer or execution only | Adviser only. Not available direct to consumer or execution only |
| Custodian | BNY Mellon Pershing Channel Islands | Northern Trust Channel Islands |
| Core product used by Cameron James | International SIPP. Also offers a general investment account and a Stocks and Shares ISA on the same platform | International SIPP |
| Withdrawal currency | Sterling only | Sterling only |
| General investment account for a US person | Not available as a standalone wrapper | Available through the dedicated US taxpayer service tier |
| US-domiciled fund access for a US person | Not accepted on the platform at all. US equity exposure is held through UK or Ireland domiciled funds | Supported for US-connected clients, and outside PFIC by definition |
| PFIC on SIPP holdings for a US person | Reporting exception applies during accumulation | Reporting exception applies during accumulation |
| Typical use case | A UK pension transfer, especially where a general investment account or ISA alongside the SIPP is wanted and you are not a US person | A UK pension transfer, and the stronger fit for a US person prioritizing a general investment account, PFIC-clean fund access or withholding tax efficiency |
Table: the two platforms compared. Confirm the current position with the provider before acting.
Which Should You Choose?
Neither platform is universally cheaper or better. The right choice depends on the size of the UK pension being transferred and how that interacts with each set of fee tiers, your expected pattern of drawdown and crystallization events, whether you want a general investment account or ISA alongside the SIPP, and, if you are a US person, whether that access, PFIC-clean investing beyond the pension and withholding tax efficiency matter to your strategy. A UK pension transfer review will model the actual cost and investment picture on both platforms for your circumstances before any transfer is recommended.
A Note From Jonathan Laws
Frequently Asked Questions
Can I self-invest in a Novia Global or Morningstar Wealth International SIPP?
No. Both platforms are adviser-only, and Cameron James does not facilitate a self-directed, execution-only approach on either. Investments are placed by the adviser under an advised or discretionary mandate.
Which platform has lower fees?
It depends on account size, investment approach and drawdown pattern rather than one being cheaper across the board. On the annual platform charge alone, Novia Global including its 0.04% fund custody charge is marginally cheaper at £250k, but Morningstar becomes the cheaper of the two by £750k and the gap widens above that. Dealing costs differ significantly by structure. A like-for-like comparison needs running against your specific figures.
Who actually holds my pension assets?
Neither Cameron James nor you personally holds them directly. Both platforms use independent Channel Islands custodians: BNY Mellon Pershing for Novia Global and Northern Trust for Morningstar. You remain the beneficial owner throughout. Cameron James directs the investment strategy as your adviser, but the custodian is responsible for safekeeping.
Does Novia Global offer a general investment account or ISA alongside the SIPP?
Yes, for non-US clients. Novia Global operates a Global Investment Account and a Stocks and Shares ISA on the same platform as its International SIPP. If you are a US person, the general investment account is not available to you as a standalone wrapper.
I am a US citizen. Can I hold a general investment account on either platform?
Not on Novia Global as a standalone wrapper. The Morningstar US taxpayer service tier can support one for a US person, and because its US-domiciled funds are not PFICs, that holding does not carry the reporting burden a UK or EU domiciled fund would create outside a pension wrapper.
I am a US citizen. Does PFIC apply to fund holdings inside these SIPPs?
Not during accumulation. A reporting exception covers interests held through a treaty-recognized foreign pension fund, and it applies on both platforms. Outside a pension wrapper the exception does not apply, which is where the US-domiciled fund access on Morningstar becomes relevant.
Which platform is better for US-domiciled fund access?
Morningstar Wealth International, through its US taxpayer service tier, gives access to qualifying US-domiciled funds for a US-connected client advised by an SEC-authorized adviser. Novia Global does not offer US-domiciled funds at all.
I am a UK expat in the US rather than a US citizen. Which section applies to me?
The US persons section. What drives the PFIC position, the general investment account restriction and the fund domicile question is US tax residence rather than nationality, so a UK national who is US tax resident faces exactly the same platform differences as a US citizen. Your UK position may differ on other points, particularly inheritance tax and long-term residence, so both sides need looking at together.
Can I move my existing SIPP between advisers without changing platform?
Yes. Changing the adviser attached to an existing SIPP on either platform does not require closing or transferring the wrapper itself in most cases. It is an administrative re-registration of the servicing agent rather than a pension transfer.
Not sure which SIPP platform fits your situation?
We will model both platforms against your actual pension value, your expected drawdown pattern and, if you are a US person, your position on US-domiciled funds, before recommending either.
Related Articles
These are existing Cameron James USA articles covering the questions that come up alongside a platform choice.
UK Pension and SIPP Transfer for US Residents
The transfer pillar. Options, US taxation of UK pension income, adviser regulation, costs and the full process.
International SIPP
How the wrapper works, and how it differs from a standard UK SIPP for a member living abroad.
Novia Global SIPP: Can You Self-Invest?
The adviser-only question answered for one of these two platforms in detail.
The IFGL SIPP Review 2026
A non-integrated alternative, where the pension wrapper and the investment platform come from different providers.
iPensions and the Momentum International SIPP Review
Another International SIPP provider, reviewed on the same criteria.
Fidelity PFIC Restrictions: What US-Connected Persons Need to Know
Why fund domicile matters so much for a US person, and what PFIC exposure actually costs.
Disclaimer: Some of the content of this communication was provided by third parties of Cameron James.
We have not verified the information contained herein, but we believe the content is reliable. None of this content should be construed as legal, accounting or tax advice. Many legal issues, accounting or tax regulations are complex and often have highly-individualized requirements, you should seek the advice of a competent professional if you have specific questions.

Jonathan Laws, ACA Ch.FCSI, Senior Independent Financial Adviser, Cameron James
“Most people arrive at this comparison wanting to know which platform is cheaper, and on the numbers the honest answer is that it depends on the size of the pension and how often you expect to touch it. Below about £500k the difference is small enough that it should not decide anything on its own. Above that, Morningstar pulls ahead on the annual charge, though dealing costs can pull it back if the portfolio is traded actively.
What actually decides it for most of the clients I see is not the fee table at all. If you are a US person, the question of whether you can hold US-domiciled funds and a general investment account is worth far more over twenty years than a few basis points, because it determines whether anything you hold outside the pension is dragging a reporting burden behind it. That is a structural difference between the two platforms rather than a pricing one, and it does not show up anywhere in a cost comparison.”