A strategy for optimising QROPS when moving from the UK to France
The situation. Ruth* had benefited from a Guernsey RATS (Retirement Annuity Trust Scheme), which qualified as a QROPS (Qualifying Recognised Overseas Pension Scheme), while living in the UK due to its favourable tax conditions.
On moving to France she needed to relocate her QROPS to a different jurisdiction to avoid double taxation.
Pension plan. Our strategy to optimise Ruth’s pension comprised:
- Changing to a Maltese QROPS, which has a DTA (Double Taxation Agreement) with France, so she can make drawdowns and only pay tax in France.
- Suggesting alternative investments, such as the French SCPI (Société Civile de Placement Immobilier), which brings regular income and favourable tax treatment.
Key takeaway. Moving a pension pot between two different QROPS, even if it is a different jurisdiction, doesn’t attract any tax so you save a considerable amount at the end.
*Names have been changed for confidentiality.

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