Why you shouldn’t leave success strategies to chance

The situation. Mr Robinson* is a French national, entrepreneur and global citizen. He has lived and worked in Australia, America, Canada and the UK, where he built up a £1,000,000 SIPP while running a business. Married with three children, he has no fixed tax residency but now plans to settle in France. Seeking compliance, he asked for advice on transferring his UK pension, minimising tax and estate planning for his family.

Key insight. Many clients believe keeping a UK pension is the safest choice. However, once residency changes risks can emerge, including exposure to UK inheritance tax and unpredictable tax on withdrawals. A proactive transfer can protect assets and create succession planning opportunities.

Succession strategy. To meet Mr Robinson’s goals, we recommended:

  • International SIPP transfer. Moving his UK pension into an International SIPP for investment flexibility.
  • UK NT code application. Ensuring no UK withholding tax on withdrawals, with taxation applied only in the country of residence.
  • Jurisdiction analysis. Reviewing options for pension lump-sum withdrawals – France proved one of the most favourable jurisdictions worldwide with an effective 15.95% tax.
  • Assurance vie investment. Placing proceeds into a French assurance vie enables Mr and Mrs Robinson to pass up to €1.515 million tax free to their children while tailoring beneficiary clauses for optimal protection.

Takeaway. By combining an International SIPP with French succession tools, Mr Robinson secured a clear, predictable strategy for his family today and in the future. 

*Names have been changed for confidentiality.

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