Written by Jonathan Laws, ACA, Ch.MCSI, Senior Independent Financial Adviser, Cameron James
If you built up benefits in a Bermuda-based pension scheme during previous employment with a multinational employer, including Shell through the Shell Overseas Contributory Pension Fund, a major reinsurer, a global bank, or a professional services firm, you may find that a Bermuda pension transfer into a more flexible, internationally recognised structure is one of the most sensible retirement planning steps you can take.
Most members never lived or worked in Bermuda. Their employer simply used the island, a long-established offshore pensions centre, as the base for its international pension plan. Many now live in the UK or overseas, holding a deferred Bermuda-based pension that is inflexible, tax-inefficient, and poorly matched to their current life. This guide explains how these plans work, why they cause problems once you leave the employer or approach retirement, and your transfer options in 2026.
Hold a Bermuda-based pension or Shell SOCPF and now live abroad?
Our advisers can review your scheme and set out which of the available structures suits where you now live. Free, and no obligation to proceed.
This guide covers
- What a Bermuda Occupational Pension is and how it works.
- Why a Bermuda-based pension can cause problems once you leave the employer or approach retirement.
- Your transfer options: UK SIPP, Malta QROPS, Malta QNUPS, Guernsey 40(ee) scheme, and ROPS.
- Why the right route depends on your residency and tax position.
- How to transfer your Bermuda pension with specialist cross-border advice.
What Is a Bermuda Occupational Pension Plan?
A Bermuda Occupational Pension Plan is a workplace pension registered under the National Pension Scheme (Occupational Pensions) Act 1998 of Bermuda and overseen by the Bermuda Pension Commission. Multinational employers in sectors such as reinsurance, global financial services, energy, and professional services have used Bermuda-registered schemes to provide retirement savings for internationally mobile staff, with the island acting as a stable, tax-neutral base for the pension rather than the place where members were necessarily employed.
Bermuda pension plans typically take one of four forms:
- Defined benefit occupational schemes.
- Defined contribution occupational schemes.
- Employer-sponsored international pension plans, the most prominent example being the Shell Overseas Contributory Pension Fund.
- Hybrid or discretionary arrangements for senior executives.
Employer and employee each contribute a required amount, typically 5 per cent of pensionable earnings, with vesting after one year of membership. Critically, no Bermuda-registered pension plan appears on the recognised overseas pension schemes notification list published by HMRC at the time of writing, which has important consequences when you come to transfer.
Why People With a Bermuda-Based Pension Struggle Once They Move On
1. No flexible access, and Pension Freedoms do not apply
Bermuda pension plans were not designed around the UK Pension Freedoms introduced in 2015. Most schemes offer no flexi-access drawdown, no ad-hoc withdrawals, no partial lump sums before age 65, and no phased retirement. Income is typically fixed, or paid in an annuity style from age 65. For anyone used to the flexibility of a modern SIPP, this is a significant restriction.
2. Bermuda pension plans are not on the HMRC ROPS list
This is a technical point that affects every Bermuda pension transfer. Because no Bermuda plan qualifies as a QROPS, a transfer is treated as a non-QROPS overseas transfer. The receiving scheme must be chosen with care, and the tax treatment depends on whether the plan ever interacted with UK tax relief.
The key technical point
Because no Bermuda plan qualifies as a QROPS, a transfer is treated as a non-QROPS overseas transfer. The receiving scheme must be selected carefully, and the tax treatment depends on whether the plan ever interacted with UK tax relief. You can check the HMRC ROPS notification list yourself; it is updated twice a month. This complexity is one of the main reasons specialist advice is essential.
3. Tax misalignment across jurisdictions
Depending on where you now live, a Bermuda pension can create real tax problems. In some countries a Bermuda plan is treated as a foreign trust, which can trigger annual taxation on growth and complex reporting. In others it may not be recognised as a qualifying pension, so lump sums can be taxed as ordinary income. For those returning to the UK, an unplanned transfer back into the UK system without advice can create unintended tax consequences, particularly for larger pots. The right treatment depends entirely on your country of residence, so local specialist tax advice is essential. Tax rules are complex and vary by individual circumstance.
4. PFIC risk for US-connected members
If you are a US-connected member, typically a US citizen or Green Card holder, the funds within your Bermuda pension are likely to be classified as Passive Foreign Investment Companies under US tax law. PFICs can trigger annual taxation on growth, even before any distribution, an interest charge on deferred gains, and mandatory Form 8621 reporting. Transferring to a qualifying UK SIPP removes this PFIC exposure, since investments held inside a UK SIPP wrapper are exempt from PFIC reporting requirements. Any US tax position should be confirmed with an appropriately qualified adviser.
5. Limited transfer options and trustee complexity
Bermuda trustees operate entirely outside the UK pension regulatory framework. They typically require a formal suitability report, confirmation of the regulatory status of the receiving scheme, and verification of your residency and tax position before approving a transfer. The process is more complex than a standard UK-to-UK transfer, and it needs a specialist who understands both the Bermuda framework and the receiving jurisdiction.
6. Legacy investment restrictions and administration delays
Once you leave the sponsoring employer, most of these schemes offer limited investment choice, slow administration, and minimal support for members managing benefits from overseas. Consolidating into a modern SIPP, QROPS, QNUPS or Guernsey 40(ee) scheme typically brings full investment flexibility, online access, and a dedicated adviser relationship.
Bermuda Pension Transfer Options: SIPP, QROPS, QNUPS, ROPS and Guernsey 40(ee)
There is no single Bermuda pension transfer route that suits everyone. The right destination depends on where you lived when contributions were made, whether the plan ever had any UK tax interaction, your current and long-term residency, whether you hold a defined benefit or defined contribution structure, and your inheritance tax planning needs. Two colleagues from the same employer, holding the same Bermuda-based scheme, can require entirely different pathways. A thorough suitability review is not optional. It is the only way to select the right structure for your circumstances.
| Transfer route | Often suits | Key consideration |
| UK SIPP | UK returnees, members with smaller or mid-sized pots, and US-connected members | Restores full UK Pension Freedoms and FCA-regulated oversight, and removes PFIC exposure for US-connected members. Most standard UK SIPP providers do not accept non-UK residents. |
| Malta QROPS | Larger pots, and cases where UK inheritance tax planning is relevant | Since 30 October 2024 the 25 per cent Overseas Transfer Charge applies unless you are resident in Malta at the time of transfer. |
| Malta QNUPS | Members whose plan never received UK tax relief, and those wanting a structure outside UK pension rules | Often used by senior executives whose contributions originated entirely outside the UK framework. |
| Guernsey 40(ee) scheme | Members whose Bermuda plan never received UK tax relief who want a non-UK structure | A separate, non-resident-only Guernsey structure. It works like a QNUPS but is not one, and it is not a QROPS. |
| ROPS (non-Malta) | Members who are not UK tax resident and want retirement savings kept entirely outside the UK system | Appropriate where the plan has no UK tax history and you intend to keep it that way. |
Option 1: Transfer to a UK SIPP
A UK SIPP is the most common destination for people returning to the UK, or who want full Pension Freedoms, FCA-regulated oversight, and transparent access to global markets from age 55, rising to 57 in April 2028. It is typically preferred for UK returnees and for members with smaller or mid-sized pots, and for US-connected members it also removes PFIC exposure. Note that most standard UK SIPP providers do not accept applications from non-UK residents. Cameron James works with globally capable platforms that accept cross-border clients. Our SIPP transfer page sets out how the destination works.
Option 2: Transfer to a Malta QROPS
A Malta QROPS is often the strongest destination where the pot is large, UK inheritance tax planning is relevant, or your Bermuda plan is treated as an offshore structure with no UK tax history. Malta remains the most stable and internationally compliant QROPS jurisdiction.
Important: the Overseas Transfer Charge
Following changes to the Overseas Transfer Charge rules on 30 October 2024, the 25 per cent charge now applies to a transfer to a Malta QROPS unless you are resident in Malta at the time of transfer. Residency alignment and timing are therefore critical for anyone considering this route.
Option 3: Transfer to a Malta QNUPS
A Qualifying Non-UK Pension Scheme, most commonly established in Malta, suits members whose Bermuda plan never benefited from UK tax relief, who want a structure entirely outside UK pension rules, or who need long-term inheritance tax planning. QNUPS are frequently used by senior executives whose contributions originated entirely outside the UK framework, which describes many Bermuda-based international pension members.
Option 4: Transfer to a ROPS
A Recognised Overseas Pension Scheme can be appropriate where you are not a UK tax resident, your Bermuda pension has no UK tax history, and you want to keep your retirement savings entirely outside the UK pension system.
Option 5: Transfer to a Guernsey 40(ee) scheme
A Guernsey 40(ee) scheme is an increasingly relevant destination for a Bermuda pension, and for many members it sits alongside a Malta QNUPS as one of the cleanest homes for a plan that never touched UK tax relief. It is a separate option in its own right, not a QNUPS and not a QROPS. The name refers to section 40(ee) of the Income Tax (Guernsey) Law, 1975, the provision under which Guernsey approves a retirement annuity trust scheme established specifically for individuals who are not resident in Guernsey. Our dedicated guide to Guernsey 40(ee) pension transfers covers eligibility, transfers in and out, and the charges in full.
Because a 40(ee) scheme is built for non-residents, it does not sit on the HMRC recognised overseas pension schemes list. Guernsey schemes were largely removed from that list in 2012, when HMRC introduced a condition that a qualifying scheme must tax residents and non-residents in the same way, which a non-resident-only structure cannot meet. So a Guernsey 40(ee) scheme is not a QROPS. It works in a broadly similar way to a QNUPS, in that it is a non-UK retirement structure funded without UK tax relief, but it is a distinct Guernsey arrangement rather than a QNUPS, which is typically established in Malta.
The attractions for an internationally mobile member are straightforward. Guernsey levies no income tax on the contributions, on the investment growth, or on the benefits paid to a qualifying non-resident member, so the fund rolls up gross and benefits are paid without deduction of Guernsey tax. Guernsey has no capital gains tax, no inheritance tax, and no wealth or gift tax. There is no cap on contributions, no cap on the level of benefits, and no prescribed investment restrictions beyond the duty of the trustee to act prudently.
One eligibility condition is worth stating plainly, because it is the point most often missed. The exemption depends on the member never having been resident in Guernsey or Jersey, and the Jersey limb catches people who spent a period working there before or after joining. It is not something a trustee can cure retrospectively, so it should be confirmed in writing before any money moves.
Guernsey also has a double taxation treaty network, including an agreement with the UK, which can help align how your pension income is taxed between Guernsey and your country of residence. For a member choosing between a Malta QNUPS and a Guernsey 40(ee) scheme, the decision usually turns on your residency, the treaty position in your country, the provider and trustee, and cost, which is exactly the kind of comparison a suitability review is designed to make.
Important: the April 2027 inheritance tax reform
From 6 April 2027 the UK is due to bring most unused pension funds and death benefits, including those held in some non-UK structures, within the scope of UK inheritance tax. Anyone considering a Guernsey 40(ee) scheme or a Malta QNUPS for inheritance tax reasons should take current advice on how these reforms affect their own position before acting.
Shell SOCPF Transfer: A Common Bermuda Pension Case
The Shell Overseas Contributory Pension Fund is the most widely held Bermuda-registered international pension plan. It is a well-funded defined benefit scheme for Shell employees working outside their home countries, registered and regulated in Bermuda. It is not a UK-registered scheme, does not appear on the HMRC ROPS list, and is not subject to UK defined benefit transfer rules, which means the standard FCA requirement for regulated advice before a defined benefit transfer does not technically apply.
However, given that SOCPF transfer values commonly range from several hundred thousand to several million pounds, specialist cross-border advice before acting remains essential. Giving up a defined benefit promise is irreversible. The main destinations are a UK SIPP, a Malta QROPS, a Malta QNUPS, or a Guernsey 40(ee) scheme, with the right option depending on your residency, tax position, retirement objectives, and whether you wish to retain UK pension framework protections. If you specifically hold SOCPF benefits, please refer to our dedicated Shell SOCPF transfer guide for detail on the unique characteristics of that scheme, including its RPI-linked increases and survivor benefits.
What This Means for You
If you hold a Bermuda-based pension and you live abroad, the question is not whether these schemes are good or bad in the abstract. It is whether this particular arrangement, with its particular access rules and tax treatment, still suits your life today. Your country of residence, whether your plan ever touched UK tax relief, your pot size, your currency, and your estate planning needs all shape the answer, and they are personal to you. Because the tax treatment turns entirely on where you live, appropriately qualified local advice should always sit alongside your UK pension advice.
The value of investments can fall as well as rise, and past performance is not a guide to future results. Tax rules are complex and vary by individual circumstance and by country. None of this is a reason to act in haste, and none of it is a reason to leave a legacy pension drifting. The sensible first step is to establish exactly what you hold and how it is treated where you live, and then to decide from an informed position. MoneyHelper offers free, impartial guidance on moving a UK pension overseas, and a specialist cross-border adviser can apply it to your own situation.
A NOTE FROM JONATHAN LAWS
How Cameron James Helps With Bermuda Pension Transfers
Cameron James is a specialist cross-border pension transfer firm. Bermuda pension transfers, including Shell SOCPF cases and other multinational employer schemes, are a core part of what we do.
Full suitability and eligibility assessment
We assess whether your Bermuda plan is transferable, which structure is most appropriate, whether tax co-ordination in your country of residence is required first, and how residency, timing, and contribution history affect your options.
FCA-regulated advice
Cameron James provides FCA-regulated pension transfer advice to its clients. Where tax co-ordination is required in your country of residence, we work alongside appropriately qualified local advisers so that your pension advice and your local tax position stay aligned.
Access to providers that accept non-UK residents
Most UK SIPP providers do not accept non-UK residents. We work with globally capable platforms that accommodate cross-border clients, including UK SIPP, Malta QROPS and QNUPS, and Guernsey 40(ee) trustees.
Transparent, fee-only advice
We charge clear, fixed fees, with no commission and no insurance bonds unless genuinely cost-effective and commission-free.
Regulated investment management
Centralised investment management using globally diversified, low-cost ETF portfolios across a range of risk profiles, built around long-term strategic asset allocation.
End-to-end transfer management
We coordinate with your Bermuda trustees, your new pension provider, and appropriately qualified tax advisers where needed. You have one point of contact throughout.
Frequently Asked Questions
In most cases yes, though the process is more complex than a standard UK pension transfer. Because no Bermuda pension plan is on the HMRC ROPS list, the receiving SIPP provider must be able to accept a transfer from a non-UK, non-QROPS overseas scheme. Eligibility also depends on your current residency and whether the plan ever interacted with UK tax rules. A regulated suitability review is essential before proceeding.
No. No Bermuda-registered pension plan currently appears on the official HMRC list of recognised overseas pension schemes. Bermuda plans do not meet the HMRC pension scheme rules, which means they must be treated as non-QROPS overseas transfers. This affects how the transfer is structured and which receiving schemes can accept the funds. The list is updated twice a month, so it is worth checking the current position rather than relying on any published summary.
A Guernsey 40(ee) scheme is a retirement annuity trust scheme approved under section 40(ee) of the Income Tax (Guernsey) Law, 1975, for individuals who are not resident in Guernsey. Guernsey does not tax the contributions, the investment growth, or the benefits paid to a qualifying non-resident member, and there is no cap on contributions or benefits. The exemption depends on the member never having been resident in Guernsey or Jersey. It is not a QROPS, and although it works in a similar way to a QNUPS it is a separate Guernsey structure in its own right rather than a QNUPS, which is typically established in Malta.
In many cases yes. A Guernsey 40(ee) scheme can receive a transfer from a Bermuda occupational pension or international pension plan, and it is often weighed up as a separate alternative to a Malta QNUPS where the plan never received UK tax relief. As with any Bermuda transfer, the Bermuda trustees will require a suitability report and confirmation of the status of the receiving scheme, and the right answer depends on your residency, tax position, and objectives. A regulated cross-border suitability review is essential before proceeding.
It depends on your residency, pot size, and retirement goals. A UK SIPP is typically best for UK returnees and members with smaller or mid-sized pots. A Malta QROPS suits larger pots where UK inheritance tax planning is relevant. A Malta QNUPS or a Guernsey 40(ee) scheme is often appropriate where the plan has no UK tax history at all. A specialist cross-border adviser can determine the right route for your circumstances.
The SOCPF is a Bermuda-regulated defined benefit scheme. Unlike UK defined benefit pensions, it is not subject to the FCA requirement for regulated advice before transfer. However, given the values involved, commonly several hundred thousand to several million pounds, specialist cross-border advice is strongly recommended and giving up a defined benefit promise is irreversible. Transfer options include a UK SIPP, a Malta QROPS, a Malta QNUPS, or a Guernsey 40(ee) scheme, with the right choice depending on residency, tax position, and objectives.
In most cases, yes. For US-connected members, typically US citizens and Green Card holders, the funds within a Bermuda pension are likely to be classified as Passive Foreign Investment Companies under US tax law. This can mean annual taxation on growth, an interest charge on deferred gains, and mandatory Form 8621 filings. Transferring to a qualifying UK SIPP removes this PFIC exposure, since investments held within a UK SIPP wrapper are exempt from PFIC reporting. Any US tax position should be confirmed with an appropriately qualified adviser.
Not under UK pension rules, since Bermuda plans are not UK-registered. The Bermuda rules permit a lump sum of up to 25 per cent of the pension account at retirement age. A UK SIPP or an appropriate QROPS follows its own rules. In every case the tax treatment of any lump sum depends on your country of residence and local tax position.
Estate Planning, Inheritance Tax Planning, and Tax Planning are not regulated by the Financial Conduct Authority.
Speak to a Cameron James Adviser
A free review of your Bermuda pension
If you hold a Bermuda Occupational Pension, a Shell SOCPF, or any other Bermuda-registered international pension and now live abroad, a Cameron James adviser will assess your transfer options, explain what is possible, and help you make an informed decision.
Related Articles
Guernsey Overseas Pension Transfer Guide.
The Guernsey pillar, covering employer schemes, IPP transfers and the routes to a SIPP, QROPS or QNUPS.
Guernsey 40(ee) Pension Transfer Guide.
The dedicated 40(ee) guide, covering eligibility, transfers in and out, and the charges in full. Awaiting publication.
Shell SOCPF Transfer Guide.
The Shell Overseas Contributory Pension Fund in detail, including RPI increases, survivor benefits and transfer options.
Jersey Overseas Pension Transfer Guide.
How members of Jersey pension schemes and international pension plans can transfer to a SIPP, QROPS or QNUPS.
UK and International SIPP for Non-UK Residents.
How an International SIPP works, who it suits, and how the transfer process runs.
Jonathan Laws, ACA Ch.FCSI, Senior Independent Financial Adviser, Cameron James
“A Bermuda-based pension is one of those arrangements that works quietly in the background while you are with the employer and then stops fitting the moment your life moves on. I speak to people who worked for Shell, for the big reinsurers, and for the global banks, most of whom never set foot on the island, and the pattern is almost always the same. The pension is inflexible, the tax treatment no longer matches where they live, and nobody has explained the options in plain terms.
My job is not to push a transfer. It is to look at your residency, your tax position, and your goals, and to tell you honestly whether a UK SIPP, a Malta QROPS, a Guernsey 40(ee) scheme, or a QNUPS actually improves your position. Sometimes it does, and by a wide margin. Sometimes staying put is right. Either way, you deserve to know.”