You have built up a self-invested personal pension, universally known as a SIPP, during your working life in Britain, and you are now settling in France for good. The question that follows is obvious: can the pension pot follow you into a French retirement plan, what will His Majesty’s Revenue and Customs, the British tax authority known as HMRC, charge on the way out, and what will the French tax office charge once you are resident here? The short answer is that there is no direct pipeline from a British SIPP into a French plan d’\u00e9pargne retraite, the French retirement savings plan universally called the PER. Every transfer must pass through the British qualifying recognised overseas pension scheme regime, universally called QROPS, and since the exemption depends on where you live and where the receiving scheme is based, a French resident faces a likely 25 percent British charge on top of French taxation on arrival. This article explains the British exit rules first, then the French entry rules, and finally how to declare the operation and challenge the bill when the administration gets it wrong.<\/p>\n
A SIPP is a British defined contribution pension wrapper: you, and sometimes your employer, pay contributions in, their growth is largely sheltered from British tax, and you draw benefits from age 55, rising to 57. A QROPS, a qualifying recognised overseas pension scheme, is an overseas pension scheme that has told HMRC it meets specific conditions and appears on HMRC’s published notification list. The British rule is blunt. Under the official British guidance<\/a>, only an overseas scheme holding QROPS status can receive the transfer. Where the receiving scheme lacks that status, the British provider may refuse the instruction or treat the payment as unauthorised, attracting a tax charge of at least 40 percent. That 40 percent figure is the unauthorised payments charge, and it applies before France has taxed a single euro.<\/p>\n In practice, the first step is therefore a verification exercise, not a transfer instruction. You open HMRC’s recognised overseas pension schemes notification list, you search for the exact French scheme your bank or insurer proposes on HMRC’s recognised overseas pension schemes notification list<\/a>, and you confirm its presence on the day you act, because schemes join and leave the list. If no French scheme appears on the list on that day, then a direct transfer from your SIPP to a French PER cannot proceed as a recognised transfer at all. Your British provider will either refuse the instruction or process it as an unauthorised payment, with the 40 percent minimum charge described above. No French legal argument can override that British classification, because it is HMRC, and only HMRC, that decides which overseas schemes qualify.<\/p>\n The transfer procedure itself is formal. HMRC’s guidance points you to form APSS 263<\/a>, which lists the information to supply before the transfer, and the completed form goes to your British scheme administrator, not to the French receiver. Deadlines matter: incomplete paperwork still outstanding 60 days after the transfer request triggers a 25 percent charge. A British saver who has already moved to France, who corresponds across two languages and two time zones, and who waits for a French institution to supply paperwork, can easily miss that 60-day window. Diarise it from the day of the request, chase both administrators weekly, and keep written proof of every document sent, because a 25 percent charge imposed for missing paperwork is far harder to challenge than a charge disputed on principle.<\/p>\n A further trap runs for five years after the transfer. If you move country within five years, HMRC requires form APSS 241 to be filed with the scheme administrator, and the outcome is mechanical: moving into the country where the QROPS is based brings a refund of charge paid, while moving away from that country triggers a 25 percent tax on the transfer. A British saver who transfers to a scheme in one country, settles in France a year later, and forgets that form, can therefore manufacture a 25 percent charge by the mere fact of moving. Before instructing any transfer, map out where you will live for the next five years, and treat a planned move to France as a reason to pause, not to accelerate. HMRC also points savers toward regulated guidance where a pension scam is suspected, and that warning deserves attention: cold calls offering to unlock a British pension into a French property deal or an offshore bond are a classic fraud pattern, and a transfer induced by fraud still leaves you liable for the tax charges described here.<\/p>\n The overseas transfer charge is a flat 25 percent levy, but its base depends on your situation. The starting point is the overseas transfer allowance, which ordinarily stands at \u00a31,073,100 according to the official British guidance<\/a>. This figure may be higher if you hold a protected allowance, for example lifetime allowance protection granted before the British lifetime allowance was abolished, so anyone with historic protection should confirm the protected figure with their administrator before doing any arithmetic.<\/p>\n Two cases then arise. First, if you exceed your available allowance but the transfer is otherwise exempt from the charge, you pay 25 percent on the excess only: where the allowance is exceeded but the transfer is otherwise exempt, the 25 percent charge falls solely on the amount above the allowance. Take a saver with the standard allowance transferring \u00a31,500,000 to an exempt arrangement: the excess is \u00a3426,900 and the charge is \u00a3106,725. Second, if you are not exempt at all, the charge falls on the whole amount: where no exemption applies, the 25 percent charge is computed on the total sum transferred. A \u00a3400,000 transfer by a saver with no exemption therefore costs \u00a3100,000 at the point of transfer, before any French tax.<\/p>\n Exemption turns principally on residence. You usually escape the charge where you transfer to a QROPS provided by your employer, and otherwise where both of the following apply: you live in the country your QROPS is based in, and the transfer does not exceed your available allowance. This residence-matching rule is the reason French residents face such difficulty. A saver living in France who transfers a SIPP to a QROPS based anywhere else does not match, and the 25 percent charge applies to the full amount transferred. Routing the money through a QROPS in a third country, a structure sometimes marketed to British expatriates, does not solve the problem for a French resident: it adds a layer of fees, a second set of scheme rules, and a five-year residence clock, while the mismatch with France remains. The only structurally clean exemptions for a French resident are an employer-provided QROPS or a France-based QROPS appearing on the HMRC list, which is why the list check described above is the decisive step.<\/p>\n One further point must be faced honestly. The France-Britain double tax treaty eliminates double taxation of taxes on income, but the overseas transfer charge is framed by Britain as a charge on the transfer itself, not as income tax on a pension payment. You should therefore assume, when budgeting, that no French tax credit will neutralise the 25 percent British charge, and that France may then tax the pension receipts themselves when they are paid out, as explained below. Planning that ignores this stacking effect understates the true cost by tens of thousands of pounds. Where the sums are large, the decision is rarely whether to transfer at all in a hurry; it is whether to leave the SIPP in Britain, draw it as a French resident under the treaty, and use the French PER separately for new savings, a comparison developed in the French section of this article.<\/p>\n Once you settle in France, the French starting point is worldwide taxation. Article 4 A of the French General Tax Code, universally called the CGI<\/a> provides: “Les personnes qui ont en France leur domicile fiscal sont passibles de l’imp\u00f4t sur le revenu en raison de l’ensemble de leurs revenus. Celles dont le domicile fiscal est situ\u00e9 hors de France sont passibles de cet imp\u00f4t en raison de leurs seuls revenus de source fran\u00e7aise.” In plain terms, a French tax resident pays French income tax, known as imp\u00f4t sur le revenu, on worldwide income, while a non-resident pays only on French-source income. Tax residence itself, called domicile fiscal, follows Article 4 B of the same code<\/a>: “Sont consid\u00e9r\u00e9es comme ayant leur domicile fiscal en France au sens de l’article 4 A : a. Les personnes qui ont en France leur foyer ou le lieu de leur s\u00e9jour principal”. The foyer means the family home, the place where your spouse and children live; the s\u00e9jour principal means the place of your main physical presence, generally where you spend more than 183 days. Professional activity in France and the centre of your economic interests complete the test, and meeting any single limb is enough. A British retiree who keeps a London flat but lives with their family in the Dordogne, is treated as French resident without hesitation.<\/p>\n The 2008 France-Britain double tax treaty then allocates the taxing right between the two States. Its Article 18<\/a> reserves pensions and similar remuneration paid for past employment to the State of residence, taxing them only there. For a private pension, including a SIPP, drawn by a French resident, that means France alone taxes the pension, and Britain must step back. The exception concerns government service: Article 19 keeps pensions paid by a Contracting State for public service taxable in the paying State, stating that pensions paid by a State, one of its local authorities, or a French statutory body for public service remain taxable only in the paying State, subject to a dual-nationality proviso. A former British civil servant, teacher in a state school, NHS employee, police officer or member of the armed forces must therefore check Article 19 before assuming France taxes everything; for ordinary private-sector SIPPs, Article 18 gives France the exclusive right.<\/p>\n Two French court decisions show how these rules bite in practice. The first principle is that the treaty never creates tax by itself. The Toulouse administrative appeal court, in a pensions dispute<\/a>, recalled that “Une convention bilat\u00e9rale conclue en vue d’\u00e9viter les doubles impositions ne peut pas, par elle-m\u00eame, directement servir de base l\u00e9gale \u00e0 une d\u00e9cision relative \u00e0 l’imposition”. The judge must first verify that French domestic law validly taxes the income, and only then ask whether the treaty blocks that tax. In that case the court examined Article 18 of the treaty at issue, which stated that “Sous r\u00e9serve des dispositions du paragraphe 2 de l’article 19, les pensions, rentes viag\u00e8res et autres r\u00e9mun\u00e9rations similaires pay\u00e9es \u00e0 un r\u00e9sident d’un Etat contractant ne sont imposables que dans cet Etat”, and held that once the taxpayers counted as residents of the other State, “les pensions de retraite de source fran\u00e7aise qu’ils ont per\u00e7ues \u00e0 partir de cette date” were, under Article 18, taxable only there. The administration’s reassessments for the later years were discharged in full. The mechanism is identical under the Franco-British treaty: establish French residence, invoke Article 18, and obtain discharge of any French attempt to deny the treaty, or symmetrically resist any British attempt to tax a pension that belongs to France.<\/p>\n French domestic law then determines how the pension is taxed. Article 79 of the CGI<\/a> states: “Les traitements, indemnit\u00e9s, \u00e9moluments, salaires, pensions et rentes viag\u00e8res concourent \u00e0 la formation du revenu global servant de base \u00e0 l’imp\u00f4t sur le revenu. Il en est de m\u00eame des prestations de retraite servies sous forme de capital.” Pensions therefore join total income taxed at the progressive scale, and the second sentence expressly pulls in retirement benefits paid as capital. Article 158<\/a> softens the blow with a flat-rate allowance, called an abattement: “Les pensions et retraites font l’objet d’un abattement de 10 % qui ne peut exc\u00e9der 4 439 \u20ac.” Each pensioner benefits individually, with a minimum allowance of 454 euros. A British saver drawing a \u00a330,000 annual SIPP income as a French resident therefore declares the sterling amount converted to euros, deducts 10 percent, and pays the progressive scale on the balance, with France alone competent under Article 18.<\/p>\n Capital payments enjoy a specific option. Article 163 bis of the CGI<\/a> allows retirement benefits paid as capital, taxable under Article 158, to be submitted “sur demande expresse et irr\u00e9vocable du b\u00e9n\u00e9ficiaire”, on the express and irrevocable request of the recipient, to “un pr\u00e9l\u00e8vement au taux de 7,5 % qui lib\u00e8re les revenus auxquels il s’applique de l’imp\u00f4t sur le revenu”, a levy at 7.5 percent discharging the income from income tax, where “Ce pr\u00e9l\u00e8vement est assis sur le montant du capital diminu\u00e9 d’un abattement de 10 %.” But the option is conditional: “Ce pr\u00e9l\u00e8vement est applicable lorsque le versement n’est pas fractionn\u00e9 et que le b\u00e9n\u00e9ficiaire justifie que les cotisations vers\u00e9es durant la phase de constitution des droits, y compris le cas \u00e9ch\u00e9ant par l’employeur, \u00e9taient d\u00e9ductibles de son revenu imposable ou \u00e9taient aff\u00e9rentes \u00e0 un revenu exon\u00e9r\u00e9 dans l’Etat auquel \u00e9tait attribu\u00e9 le droit d’imposer celui-ci”. A single payment, with proof that contributions were deductible or linked to exempt income in the State entitled to tax that income, opens the 7.5 percent route; a split payment closes it.<\/p>\n A Bordeaux appeal decision from December 2025<\/a> shows what happens when the conditions fail. An employee of an international group received 411,091 euros from an employer pension arrangement, took part of the balance in cash and transferred the remainder within the company plan. The administration denied the 7.5 percent levy and reassessed for 173,250 euros. The court held that “la somme de 411 091 euros per\u00e7ue au cours de l’ann\u00e9e 2015 ne pr\u00e9sente pas le caract\u00e8re d’une pension de retraite vers\u00e9e en capital mais rel\u00e8ve de la cat\u00e9gorie des revenus de capitaux mobiliers<\/a>“, investment income, because the arrangement let the employee take the accumulated sums immediately on departure, without any duration or age condition, and its purpose was not to pay a pension but to hand over the accumulated balance at once. The court added the general lesson that “le l\u00e9gislateur a entendu ouvrir aux contribuables personnes physiques titulaires de prestations de retraite vers\u00e9es sous forme de capital qui y trouvent avantage la facult\u00e9 d’opter, en lieu et place d’une taxation au bar\u00e8me progressif de l’imp\u00f4t sur le revenu, pour l’application aux sommes en cause d’un pr\u00e9l\u00e8vement forfaitaire de 7,5 % lib\u00e9ratoire de l’imp\u00f4t sur le revenu.” Reclassification as investment income is expensive: the progressive scale can be replaced by the 30 percent flat rate on investment income<\/a>, and the 10 percent pension allowance is lost. For a British saver, the warning is direct. Cashing out a SIPP in tranches, or taking a transfer value partly in cash before moving it on, risks the same reclassification in France. A scheme-to-scheme transfer of the whole pot, documented as such, preserves the pension character; a fragmented cash exercise invites the administration to see investment income instead.<\/p>\n Social levies complete the picture. Article L. 136-6 of the Social Security Code<\/a> states: “Les personnes physiques fiscalement domicili\u00e9es en France au sens de l’article 4 B du code g\u00e9n\u00e9ral des imp\u00f4ts sont assujetties \u00e0 une contribution sur les revenus du patrimoine assise sur le montant net retenu pour l’\u00e9tablissement de l’imp\u00f4t sur le revenu”. French residents therefore face social contributions on investment income, while pensions of persons affiliated to a foreign health regime may escape part of them, a point to verify on your own facts rather than assume. Where a British saver wants to build fresh French retirement savings instead of transferring, the PER is the natural vehicle. The Monetary and Financial Code<\/a> opens it plainly: “Les personnes physiques peuvent verser des sommes dans un plan d’\u00e9pargne retraite.” Voluntary payments into a PER are deductible from overall income under Article 83 of the CGI<\/a>, which extends the deduction to “des versements mentionn\u00e9s au 3\u00b0 de l’article L. 224-2 du code mon\u00e9taire et financier dans un plan d’\u00e9pargne retraite mentionn\u00e9 \u00e0 l’article L. 224-13 ou \u00e0 l’article L. 224-23 du m\u00eame code.” For readers weighing a lump-sum drawdown against a transfer, our companion analysis of British pension lump sums and Crown pensions under the same treaty<\/a> sets out the parallel calculations. Leaving the SIPP in Britain, drawing it taxed only in France under Article 18 with the 10 percent allowance, and funding a PER separately with deductible contributions, will often beat a costly cross-border transfer.<\/p>\nB. How the 25 percent overseas transfer charge and the allowance actually work<\/h3>\n
II. How France taxes the pension money once you live here<\/h2>\n
A. Why France claims the taxing right, and what it does with lump sums and transfers<\/h3>\n
B. How to declare the transfer in France and challenge a wrong tax bill<\/h3>\n