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UK Private Pension - Brexit Issue
Posted: Wed Jan 22, 2025 3:58 pm
by SilkeT
Dear All,
Here I am again with a question about a UK Private Pension. My husband (UK citizen, resident in Germany) is approaching retirement age. He has a SIPP with a UK pension provider. He was told today that the pension provider where his SIPP is held cannot provide him with an annuity or any other investment scheme to his residency in Germany, but he has to transfer his "pension pot" to a "Qualified Overseas Pensions Scheme Provider".
We are at a loss where to go from here. Are there any British Citizens, resident in Germany, who have had to go through this procedure and who can point us in a direction - where do we find these "Qualified Overseas Pensions Scheme Providers" or is there anyone out there who managed to find a UK based company that can provide annuities/ other investments for UK private pensions to non-UK residents post Brexit?
Many Thanks
Silke
Re: UK Private Pension - Brexit Issue
Posted: Wed Jan 22, 2025 5:03 pm
by Fraufruit
Have you read the other threads about SIPP? If not, just put it in the search bar.
Re: UK Private Pension - Brexit Issue
Posted: Wed Jan 22, 2025 5:09 pm
by SilkeT
Yes, I have. They all address the 2025 changes in tax law relating to SIPPs or a post from myself, which asked a different question. I cannot find any posts that deal with the question I asked here. If there is one, can you kindly point me to it? Thank you.
Re: UK Private Pension - Brexit Issue
Posted: Wed Jan 22, 2025 5:10 pm
by SilkeT
Fraufruit wrote: ↑Wed Jan 22, 2025 5:03 pm
Have you read the other threads about SIPP? If not, just put it in the search bar.
Yes, I have. They all address the 2025 changes in tax law relating to SIPPs or a post from myself, which asked a different question. I cannot find any posts that deal with the question I asked here. If there is one, can you kindly point me to it? Thank you.
Re: UK Private Pension - Brexit Issue
Posted: Wed Jan 22, 2025 5:59 pm
by Fraufruit
You're welcome. Just wanted to make sure you weren't missing important information.
I feel for you people having to sort all of this out.
Re: UK Private Pension - Brexit Issue
Posted: Wed Jan 22, 2025 7:04 pm
by yesterday
I do not know much about this !!!
I just had a look at
https://www.cjfinance.co.uk/pension-tra ... %20SIPP%20(Self%2DInvested,before%20and%20during%20their%20retirement.
They seem to offer advice on what to do with SIPP for non residents.
As said I do not know much about it, but I would try to consult with many companies offering to help and maybe pick one, ofcourse its a risk
I got this info type doing a google search for "SIPP for non uk residents", which you can do as well.
There are many hits which talk over the options, try to look at at lot of them and see if there is a common way for how this situation is handled.
I wish you luck
Re: UK Private Pension - Brexit Issue
Posted: Wed Jan 22, 2025 7:17 pm
by SilkeT
yesterday wrote: ↑Wed Jan 22, 2025 7:04 pm
I do not know much about this !!!
I just had a look at
https://www.cjfinance.co.uk/pension-tra ... %20SIPP%20(Self%2DInvested,before%20and%20during%20their%20retirement.
They seem to offer advice on what to do with SIPP for non residents.
As said I do not know much about it, but I would try to consult with many companies offering to help and maybe pick one, ofcourse its a risk
I got this info type doing a google search for "SIPP for non uk residents", which you can do as well.
There are many hits which talk over the options, try to look at at lot of them and see if there is a common way for how this situation is handled.
I wish you luck
Thank you for your efforts! Really appreciate it. There are indeed many companies that offer “advice” for the transfer of UK pensions abroad.
The issue I have is two fold:
1. Can we avoid having to transfer the pension and find a UK provider that offers annuities to non-UK residents?
2. If the answer to the above is no, who are the UK recognized providers in Germany? If we end up with a non-UK recognized providers, the financial (“penalty tax”) implications can wipe out a huge part of the pension pot.
Re: UK Private Pension - Brexit Issue
Posted: Wed Jan 22, 2025 7:47 pm
by GaryC
@millgor may be able to help as he has been through the process and ended up taking the whole pot as a lump sum, I think.
Re: UK Private Pension - Brexit Issue
Posted: Wed Jan 22, 2025 10:56 pm
by sam
The provider won't sell an annuity. I get that, they're not licensed to sell financial products in the EU.
You could look at a QROPS to Germany but then you'll have more German pension, rather than UK pension with UK personal allowance etc applying. If you can find a German provider that wants to take it.
Or another UK provider but maybe they're all in the same boat when it comes to selling annuities to non residents.
Cashing out is a possible option but brings all your UK tax in one year...
So ...
What about putting the UK pension into drawdown? The existing provider isn't selling a new product, and you can take income out while leaving the rest invested. There may be some charges though.
Re: UK Private Pension - Brexit Issue
Posted: Thu Jan 23, 2025 1:02 am
by SilkeT
sam wrote: ↑Wed Jan 22, 2025 10:56 pm
The provider won't sell an annuity. I get that, they're not licensed to sell financial products in the EU.
You could look at a QROPS to Germany but then you'll have more German pension, rather than UK pension with UK personal allowance etc applying. If you can find a German provider that wants to take it.
Or another UK provider but maybe they're all in the same boat when it comes to selling annuities to non residents.
Cashing out is a possible option but brings all your UK tax in one year...
So ...
What about putting the UK pension into drawdown? The existing provider isn't selling a new product, and you can take income out while leaving the rest invested. There may be some charges though.
Thank you for your suggestion!
The tax burden when taking it out in a lump sum is prohibitive - in relation to UK taxes and the effect of the Progressionsvorbehalt in Germany.
I was hoping that someone knows of UK providers who still offer annuities to non-UK residents.
As for putting it into drawdown, but it has two major drawbacks:
- one cannot rely on a stable annuity/ the pension funds remains subject to value fluctuations
- I had understood that at a certain age (75 years?) it is obligatory to take out an annuity, ie the problem I describe in this threat is only postponed, not resolved.
This all feels like a massive nightmare.
Re: UK Private Pension - Brexit Issue
Posted: Fri Jan 24, 2025 11:02 pm
by sam
SilkeT wrote: ↑Thu Jan 23, 2025 1:02 am
1) one cannot rely on a stable annuity/ the pension funds remains subject to value fluctuations
2) I had understood that at a certain age (75 years?) it is obligatory to take out an annuity, ie the problem I describe in this threat is only postponed, not resolved.
1) is true and either an advantage or disadvantage of drawdown depending on whether annuity rates are good or keeping your money invested (in low risk things) is better.
2) This is no longer law. Went out with "pension freedoms". However in any event taking money out by drawdown does not mean you have to stagger it over your life like an annuity would. If your husband is coming up to 65 he could take 10% each year for ten years to get everything over to Germany by the time he's 75 if that's what's right for you. Would still stagger the impact on his/your joint Progressionsvorbehalt.
QROPS - just be careful googling it as there are "pension liberation" scammers who try to get people into schemes with super high fees etc. They may pay for search ads etc.