Many expats still hold a deferred Guernsey Overseas Pension or International Pension Plan (IPP) from previous employment with multinational employers such as BWCI Group, Deutsche Bank, De Beers, and major energy and financial institutions. These plans worked well during employment, but they were never designed for long-term global portability.
If you now live in the UK, EU, US, Middle East or Asia, you may find your Guernsey pension tax-inefficient, inflexible, and difficult to access, especially compared to modern UK and international pension solutions.
This updated 2025 guide explains:
- Why Guernsey Overseas Pensions & IPPs are restrictive
- The most common transfer options: UK SIPP, Malta QROPS, Malta QNUPS and other ROPS
- Why suitability varies by your residency, employer history, funding source and tax status
- How Cameron James helps expats restructure their pensions into flexible, compliant arrangements
What Is a Guernsey Overseas Pension or International Pension Plan (IPP)?
Guernsey has long been a specialist jurisdiction for non-UK, non-EU employer pension schemes used for internationally mobile employees. These are often labelled as:
- Overseas Pension Schemes
- International Pension Plans (IPPs)
- Non-Resident Employee Schemes
- QROPS
- Delisted QROPS
- QNUPS
- Section 150/157 Occupational Schemes
- International Savings or Retirement Plans
They offer a tax-deferred accumulation environment, which suited corporate mobility. However, once you leave employment, or leave the Channel Islands, these schemes frequently clash with local pension and tax rules.
In short:
They’re excellent during your working life. They become restrictive when you start wanting to access or consolidate the money.
Why Guernsey Overseas Pension / IPP Members Struggle After Leaving Guernsey
1. No Flexible Access or Pension Freedoms
Most Guernsey schemes do not offer:
- Flexi-access drawdown
- Ad-hoc withdrawals
- Partial lump sums
- Phased retirement
Income is normally fixed, annuity-style, or locked until a set age.
For expats used to UK Pension Freedoms (post-2015), these restrictions come as a shock.
2. Limited Transfer Options Without Professional Advice
Trustees often sit in a regulatory grey zone, not fully UK pensions, but not fully recognised overseas either. Because of this, trustees often require:
- A suitability report
- Tax advice waivers
- Confirmation of the receiving scheme’s regulatory status
This process is significantly more complex than transferring UK pensions.
3. Tax Misalignment for UK, EU & US Residents
Depending on your country of residence, your Guernsey pension may be treated as:
- A foreign trust (commonly in the US)
- A non-recognised pension (many EU countries)
- A misaligned offshore plan (UK returnees)
This affects:
- Annual tax on growth
- Whether lump sums are treated as taxable income
- PFIC reporting (US)
- Compliance penalties
For many EU and US residents, the tax burden becomes substantial.
4. Outdated Investment Options
Most IPPs use:
- Legacy employer funds
- Conservative or opaque portfolios
- Limited risk profiling
Modern expat SIPPs and QROPS typically offer global ETF-based, low-cost portfolios, which many clients prefer.
5. Administration Delays & Employer Legacy Issues
Because these plans originated through employers, administration is often:
- Slow
- Fragmented
- Difficult to navigate
This becomes a problem when members want to access funds, consolidate pensions, or manage income in retirement.
Transfer Options: UK SIPP, Malta QROPS, Malta QNUPS, ROPS & Other Structures
One of the biggest myths is that Guernsey Overseas Pensions/IPPs have one transfer route. The truth is: every case is different.
Your best destination depends on:
- Where you lived when contributions were made
- Whether the plan ever interacted with UK pension rules
- Your long-term residency
- Whether the employer or employee received UK tax relief
- Inheritance tax planning needs
- Whether you want to avoid UK pension rules entirely
This is why two colleagues from the same employer can require entirely different transfer pathways.
1. Transfer to a UK SIPP
A UK Self-Invested Personal Pension is suitable if you:
- Are returning to the UK
- Want full Pension Freedoms
- Want FCA oversight
- Want transparent, low-cost access at age 55/57
However, for large pots (common with Guernsey IPPs), a UK SIPP may not be the most tax-efficient solution, particularly for non-UK residents.
2. Transfer to a Malta QROPS
A Malta QROPS is often optimal where:
- The pension pot is large
- UK inheritance tax (IHT) planning is relevant
- Your Guernsey plan is viewed as an offshore structure
- You require EU-recognised pension status
- You live in (or will move to) the EU
Malta remains the most stable and internationally compliant QROPS jurisdiction for expats.
3. Transfer to a Malta QNUPS
A QNUPS may suit you if:
- Your plan never qualified for UK tax relief
- You want a pension structure outside UK pension rules
- You have complex cross-border tax requirements
- You need long-term inheritance tax protection
QNUPS are common for senior executives whose contributions originated outside the UK pension framework.
4. Transfer to a ROPS (Recognised Overseas Pension Scheme)
A ROPS may be appropriate when:
- You are not UK-tax resident
- Your pension has zero UK tax history
- You want to keep your retirement outside the UK pension system
- Local tax advisers prefer a fully overseas structure
This is common for Australian, Canadian and Asian residents.
Why US, EU & UK Residents Require Different Transfer Strategies
US Residents
The US often classifies Guernsey schemes as:
- Foreign grantor trusts
Which may require:
- Form 3520 / 3520-A
- PFIC reporting
- Annual taxation on growth
Migrating into a US-compatible SIPP structure can dramatically simplify tax compliance.
EU Residents
Each EU country has its own rules:
- Spain often taxes lump sums heavily
- Portugal may apply 10% tax under NHR
- France may not recognise Guernsey schemes as pensions
- Italy, Cyprus and Malta offer favourable frameworks
Aligning the pension with a recognised EU jurisdiction is essential.
UK Returnees
Returning UK residents usually benefit from a UK SIPP, unless:
- The pot is large, or
- They have sizeable UK estates (IHT considerations)
In these cases, a Malta QROPS or QNUPS may be more suitable.
How Cameron James Helps With Guernsey Overseas Pension & IPP Transfers
Cameron James specialises in cross-border pension transfers for expats across the UK, EU, US and beyond. These employer-style Guernsey schemes are something we handle daily.
1. Full Eligibility & Suitability Assessment
We determine:
- Whether your Guernsey plan is transferable
- Whether SIPP, QROPS, QNUPS or ROPS is suitable
- Whether tax advice is required
- How residency, timing and funding affect the route
2. Cross-Border Regulation in the UK, EU & US
We operate under:
- FCA regulation (UK clients)
- MiFID II / IDD (EU clients)
- SEC regulation (US clients & US expats)
This ensures compliant advice for globally mobile professionals.
3. Providers That Accept Non-UK Residents
Most UK SIPP providers do not accept non-UK residents. We work only with globally capable platforms that do.
4. Transparent, Fee-Only Advice
- No commissions
- No insurance bonds, unless cost-effective and commission free
- No opaque products
Everything is clear and regulated.
5. Regulated Investment Management
We provide centralised investment management using:
- Globally diversified ETFs
- Multiple risk profiles
- Long-term strategic asset allocation
6. End-to-End Transfer Management
We coordinate communication with:
- Guernsey trustees (e.g., BWCI)
- Your new pension provider
- International tax advisers
You have a single point of contact throughout.
Next Step: Free Review of Your Guernsey Overseas Pension / IPP
If you hold a Guernsey Overseas Pension or International Pension Plan from a multinational employer and now live abroad, your options are likely far broader than you realise.
A regulated transfer could allow you to:
- Access flexible drawdown
- Reduce tax exposure
- Improve investment control
- Remove administrative barriers
- Consolidate multiple schemes
- Simplify global retirement planning
Cameron James can provide a free, no-obligation review and help you determine whether a SIPP, QROPS, QNUPS or ROPS is most suitable for your circumstances.
FAQ: Guernsey Overseas Pension & International Pension Plan Transfers
1. Can I transfer my Guernsey Overseas Pension or IPP to a UK SIPP?
Often yes, but only if your plan qualifies as a UK-recognised pension. Eligibility depends on where contributions were made, whether UK tax relief ever applied, and your current residency. A suitability review is essential because some schemes must go to QROPS/QNUPS instead.
2. Is a Malta QROPS better than a UK SIPP for Guernsey pensions?
A Malta QROPS can be more suitable for:
- Larger pension pots
- Clients living in the EU
- Expats concerned about UK inheritance tax
- Clients whose Guernsey IPP is treated as an offshore structure
A UK SIPP is typically preferred for UK returnees or smaller pots. The jurisdiction must align with your residency and tax considerations.
3. What is the difference between a Guernsey IPP and a UK pension?
A Guernsey IPP is an employer-sponsored international plan, not a UK-registered pension. It usually lacks flexible access, Pension Freedoms, and transparent investment options. UK pensions, such as SIPPs, are protected under FCA regulation and allow flexible drawdown from age 55/57.
4. Are Guernsey Overseas Pensions taxable when I move abroad?
Yes, potentially. Taxation depends entirely on your new country of residence. For example:
- US residents may face foreign trust classification and PFIC reporting
- EU residents may face lump-sum taxes or non-recognition of the plan
- UK returnees may trigger unintended tax consequences if not transferred appropriately
Tax treatment varies, which is why cross-border advice is essential.
5. Can I take a tax-free lump sum from a Guernsey Overseas Pension?
Not always. Many Guernsey schemes do not follow UK PCLS rules. Some countries may also tax the lump sum as income. A transfer into a recognised structure (SIPP or QROPS) may restore more flexible and tax-efficient withdrawal options.