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SIPP or QNUPS: How to Choose the Right International Pension Structure
- Jul 9
- 2 min read
For globally mobile clients planning retirement across more than one jurisdiction, two structures come up repeatedly: the Self-Invested Personal Pension (SIPP) and the Qualifying Non-UK Pension Scheme (QNUPS). Both offer flexibility that domestic pension arrangements often can't, but they solve different problems.
What Is a SIPP?
A SIPP is a UK-regulated personal pension that gives the holder significantly wider investment control than a standard workplace pension, access to a broad range of funds, equities, bonds, and in some cases commercial property. It remains a UK pension arrangement, subject to UK pension rules, even when the holder is living abroad.
What Is a QNUPS?
A QNUPS is a non-UK pension scheme that meets HMRC's recognition requirements, most notably around inheritance tax. Assets held within a properly structured QNUPS generally sit outside the holder's UK estate for inheritance tax purposes, which is the primary reason it's used by UK-connected individuals living or planning to live overseas long-term.
The Key Decision Points
Ongoing UK tax residency: a SIPP typically makes more sense if UK tax residency is expected to continue or resume.
Inheritance tax exposure: a QNUPS is generally more relevant where UK inheritance tax exposure is a specific planning concern.
Contribution flexibility: QNUPS structures often allow larger and more flexible contributions than UK pension annual allowance rules permit for a SIPP.
Long-term residency plans: clients who have permanently left the UK, or never had significant UK pension savings, may find QNUPS structures better aligned with their situation from the outset.
Why This Isn't an Either/Or in Every Case
Some clients hold both, an existing SIPP built up during a UK career, alongside a QNUPS established for ongoing international contributions. The right combination depends entirely on the individual's residency history, where they intend to retire, and how much of their existing pension wealth already sits in UK-regulated schemes.
This is a decision that benefits from proper advice rather than a generic rule of thumb, the tax treatment of both structures depends heavily on the individual's specific circumstances and current residency status. An advisor working through this with a client should start by mapping out where the client is likely to be tax resident over the next decade, not just where they are today.
International Assurance Limited PCC does not provide financial, investment, tax, or legal advice. All decisions should be made in consultation with appropriately qualified professional advisors, based on the client's individual circumstances, objectives, risk profile, and jurisdictional requirements.