Resources & Insights

Neil Robbirt on the 2024–26 Pension Rule Changes for Expats

By QROP Direct Editorial Team · Interview with Neil Robbirt, Chairman of Global Investments Group · Reviewed 2026-06-16

Neil Robbirt on the 2024–26 Pension Rule Changes for Expats

The following is an interview with Neil Robbirt, Chairman of Global Investments Group. His views are provided for general education and information only and are not personal financial, tax or legal advice. The figures and rules cited reflect the position as at 2026 and can change. Always take regulated advice in the relevant jurisdiction before acting.

QROP Direct: The last couple of years have seen an unusual concentration of pension changes. Which matter most for expats?

There are three I'd put on every expat's radar. The Overseas Transfer Charge change in October 2024; the abolition of the Lifetime Allowance from April 2024 and what replaced it; and the bringing of pensions into the scope of inheritance tax from April 2027. Individually each is significant. Together they change the calculus for a lot of cross-border pension planning, and the 2027 change in particular is one people are not yet paying enough attention to.

QROP Direct: Start with the Overseas Transfer Charge. What changed?

Until 30 October 2024 there was a broad exemption from the 25% Overseas Transfer Charge for transfers to schemes established in the EEA or Gibraltar. A great deal of routine planning depended on that exemption. It was removed. The position now is essentially a residency match: to avoid the charge you generally need to be tax resident in the same country in which the receiving QROPS is established.

The effect is that transfers which were previously straightforward can now trigger a 25% charge if the residency doesn't line up. The single most important habit this creates is to check the Overseas Transfer Charge position against current HMRC guidance at the moment of transfer — not against what an adviser remembered from a year earlier. We saw people caught out in the immediate aftermath precisely because they acted on the old assumptions.

QROP Direct: And the abolition of the Lifetime Allowance — was that simply good news?

It's more nuanced than the headline suggested. The Lifetime Allowance charge — the tax on the total value of your pension above a threshold — was abolished from 6 April 2024. But it wasn't replaced by "no limits." It was replaced by two new allowances that cap the tax-free element. The Lump Sum Allowance limits the tax-free cash you can take to £268,275. The Lump Sum and Death Benefit Allowance caps tax-free lump sums, including those paid on death, at £1,073,100.

So the value you can accumulate is no longer penalised, which genuinely helps people with larger pots, but the tax-free portion is still bounded. And income you draw is taxable as normal, which for an expat means it's taxable according to your country of residence and the relevant double taxation agreement. People who heard "the Lifetime Allowance is gone" and assumed their whole pension was now tax-free have misunderstood it.

QROP Direct: The 2027 inheritance tax change — why are you flagging it so strongly?

Because it reverses one of the most useful features pensions have had. For years, unused pension funds generally sat outside your estate for inheritance tax purposes. That made a pension an efficient way to pass wealth to the next generation — you could draw on other assets first and leave the pension as a kind of family legacy.

From 6 April 2027, legislation brings most unused pension funds and death benefits within the scope of inheritance tax. For someone with a substantial unused pension and a UK-connected estate, that's a material change to the after-death position. It interacts with domicile, with the rules of your country of residence, and with double taxation — so it's exactly the kind of area where generic planning fails and individual advice earns its keep. The key point is that 2027 is close enough that the planning conversation should be happening now, not in 2027.

QROP Direct: Taken together, what's the practical message for an expat reading this?

Review, don't react. Each of these changes can alter the right course of action, but none of them is a reason to rush into an irreversible decision. The Overseas Transfer Charge change makes verifying your residency position essential before any QROPS transfer. The Lifetime Allowance reform changes how you think about tax-free cash and the timing of drawing it. And the 2027 inheritance tax change should prompt anyone with a significant unused pension to revisit how their pension fits into their estate plan.

What ties them together is that the cost of acting on out-of-date information has gone up. The rules are moving, and advice that was sound two years ago may no longer be. A periodic review with a qualified, cross-border-aware adviser is the single most valuable habit in this environment.

QROP Direct: A final thought?

Don't let the volume of change paralyse you, and don't let it stampede you either. The expats who do well through a period like this are the ones with a plan that gets reviewed as the rules move — not the ones who either ignore the changes or lurch from one to the next. Steady, informed, reviewed. That's the whole of it.

Summary: The Three Changes Every Expat Should Track

1. Overseas Transfer Charge (from 30 Oct 2024) — EEA/Gibraltar blanket exemption removed; main exemption is now residency in the QROPS country. Verify before any transfer.
2. Lifetime Allowance abolition (from 6 Apr 2024) — replaced by the Lump Sum Allowance (£268,275) and Lump Sum & Death Benefit Allowance (£1,073,100); income remains taxable.
3. Pensions in inheritance tax (from 6 Apr 2027) — most unused pension funds brought within IHT scope; review estate planning now.
4. Overarching message — review your plan as the rules move; the cost of acting on out-of-date information has risen.