Pension contributions for overseas customers

These FAQs are for financial advisers only. They mustn’t be distributed to, or relied on by, customers. They are based on our understanding of legislation at the date of publication.

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If a member moves overseas, they may be able to:

  • continue to contribute to their plan (subject to certain conditions).
  • transfer their plan to a qualifying recognised overseas pension scheme (known as a QROPS).
  • leave the plan as it is until retirement, and have benefits paid to them overseas.

The first of these options is covered in the remainder of this FAQ.

Yes, this is possible although what can be paid depends on who wants to make contributions and whether the member’s earnings will be subject to UK income tax on moving abroad.  

If a member continues to have relevant UK earnings chargeable to UK income tax (see the section of HMRC’s Pensions Tax Manual titled ‘Earnings that attract tax relief' here(Opens new window)) after moving abroad, then personal contributions can continue to be made as before. The limit on personal contributions for tax relief purposes would still be the greater of £3,600 gross pa and 100% of their relevant UK earnings in that tax year.

It’s important to note that relevant UK earnings are to be treated as not being chargeable to income tax if, due to a double taxation agreement, they are not taxable in the United Kingdom.

If a member doesn’t have relevant UK earnings chargeable to UK income tax on moving abroad (e.g.  they’re being paid and taxed overseas), then they will only be able to receive tax relief on personal contributions of up to £3,600 gross pa for five full tax years following the tax year in which they move abroad. The member must have been resident in the UK when they became a member of the pension scheme. 

Please note that most providers do not accept contributions that are not eligible for tax relief (for members under the age of 75), so the maximum tax relievable contribution is also the maximum contribution that providers will accept.

A UK employer can continue to contribute whether a person has relevant UK earnings or not, and corporation tax relief should be granted where contributions have been made wholly and exclusively for the purposes of the employer’s trade, profession or investment business. The employer’s local inspector of taxes will deal with any claim for tax relief. If contributions are to be made by a non-UK resident employer, then UK corporation tax relief would not normally be allowable, but it may be possible for the employer to make a claim under the tax system of the country in which they are based.

In practice, if a member moves abroad they will need to inform their pension provider so that appropriate action can be taken depending on the person's circumstances. 

An example

Rebecca holds a group personal pension (GPP) plan. She makes personal contributions of £6,000 pa and her employer also contributes £6,000 pa, and her current salary is £60,000.

In March 2020, she moves to Germany to work. She remains employed by the UK-based company but is now taxed in Germany. The following table shows the how the contributions would have to change going forward, assuming the intention was for the employee and employer contributions to continue:

Tax year Earnings taxed in the UK Gross annual personal contributions Gross annual employer contributions
2018/19 £60,000 £6,000 £6,000
2019/20 £60,000 £6,000 £6,000
2020/21 Nil £3,600* £6,000
2021/22 Nil £3,600* £6,000
2022/23 Nil £3,600* £6,000
2023/24 Nil £3,600* £6,000
2024/25 Nil £3,600* £6,000
2025/26 Nil Nil £6,000

* As her provider can only accept contributions that are eligible for tax relief (for members under the age of 75), her personal contributions must reduce to the maximum of £3,600 for the first five full tax years after she leaves the UK, then reduce to nil after this.

Yes, this is possible although what can be paid depends on who wants to make contributions and whether a member’s earnings will be subject to UK income tax on moving abroad.  

Personal contributions to an occupational scheme are made under the ‘net pay’ arrangement. This means that they are deducted from gross pay before income tax is calculated so an employee will receive tax relief on any contributions at their highest marginal rate. If an employee is going to be working for the same employer and will continue to have relevant UK earnings chargeable to UK tax on moving abroad, then personal contributions can continue to be made as before under the ‘net pay’ arrangement if the employee remains on the UK payroll. The limit on personal contributions for tax relief purposes would be the greater of £3,600 gross pa and 100% of relevant UK earnings. 

If an employee doesn’t have relevant UK earnings chargeable to UK tax on moving abroad (e.g. they will be moving onto the payroll of an overseas employer), then personal contributions will not be eligible for UK tax relief through the ‘net pay’ arrangement as the employee is not likely to be on a UK payroll. This means that the employee can’t use the ‘net pay’ arrangement to pay £3,600 for five tax years after they leave the UK – Relief at Source is the only method by which someone without relevant UK earnings chargeable to UK tax can claim tax relief on contributions up to £3,600. See our question on Can contributions continue to a member's existing personal pension or stakeholder arrangement? 

A UK employer can continue to make employer contributions for an employee seconded abroad and corporation tax relief should be granted where contributions have been made wholly and exclusively for the purposes of the employer’s trade, profession or investment business. The employer’s local inspector of taxes will deal with any claim for tax relief. 

In practice, the only likely situation where contributions will continue to a UK occupational scheme on a person moving abroad is where an employee is moving abroad to work for the same employer or an employer in the same international group. Occupational schemes are not as flexible as personal pensions in being able to accommodate changes in someone’s circumstances.

Unless a pension provider has the necessary Financial Conduct Authority (FCA) authorisation to accept new pension business from people living abroad, it’s generally not possible for personal or employer contributions to re-start or be increased to an existing personal pension or stakeholder arrangement after a member has moved overseas. For example, if someone was paying £100 per month gross as a personal contribution and then moved abroad, they could continue paying that amount or a lower amount for the five full tax years after they move abroad (this assumes they will have no relevant UK earnings after leaving the UK). In other words, a member couldn’t ask their provider to increase their contributions after they move abroad (for example, up to the £3,600 pa gross limit allowed under HMRC guidance). Similarly, a request to make a single contribution (as either a personal or employer contribution) or to transfer funds to another UK pension arrangement would not be possible.

Note: Providers are unlikely to be able to accept new pension business from US persons (e.g. a US citizens, US taxpayers) due to US legislation.

Contributions to, or benefit accrual under, a registered pension scheme will count towards the annual allowance, the money purchase annual allowance (if a member has flexibly accessed any of their pension benefits) and the tapered annual allowance (for high earners). The normal rules about benefit crystallisation events will apply so most benefits will be tested against the lifetime allowance. 

Any annual or lifetime allowance tax charge is payable regardless of where the member lives. These charges are not covered by any double taxation agreement in place between the UK and the country of residence.

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