By Jonathan Laws, ACA Ch.FCSI — Senior Independent Financial Adviser, Cameron James
If you hold a ReAssure pension and you live outside the UK, you may already have discovered that the standard options available to UK residents are not available to you. ReAssure is one of the largest holders of legacy UK pension policies in existence, administering arrangements that originated with companies such as Guardian, AXA, Zurich, and others. For non-UK residents, the inability to access a ReAssure pension flexibly from abroad means that a transfer to a more appropriate structure is, in practice, almost always the only workable path forward. This guide explains why, what your options are, and how a transfer to an International SIPP works.
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ReAssure Is a Legacy Closed Book Provider: What That Means in Practice
Understanding what ReAssure is helps explain why it behaves the way it does. A closed book insurer acquires large blocks of existing policies from other providers, typically when those providers wish to exit a particular market or restructure their business. ReAssure has done this at scale. The result is a book of business encompassing millions of pensions originally designed under the product terms, systems, and technology of previous decades. If you have an old workplace or personal pension from a previous decade, there is a reasonable chance it ended up with ReAssure following one of those acquisitions.
ReAssure Limited is authorised by the Prudential Regulation Authority and regulated by the PRA and Financial Conduct Authority (FCA firm reference number 110495), and now forms part of Standard Life plc. Confirmation of its regulatory status is available on the FCA Register entry for ReAssure Limited. The firm's regulatory standing is not in question. The issue, for non-UK residents, is the service model that comes with a legacy closed book of business.
The majority of ReAssure pension policies are legacy schemes dating to before 2010. Many predate the pension freedoms reforms of April 2015 entirely. These policies were designed when annuity purchase was the default expectation at retirement, when flexible drawdown did not exist in its current form, and when the idea that a pension holder might be living in Dubai, Sydney, or Toronto when they came to access their pension was not a design consideration.
ReAssure does not offer a modern open-architecture SIPP in the way that contemporary platforms do. Its product range reflects what was available when those policies were originally written. For a UK resident who is content to accumulate and eventually purchase an annuity, this may be manageable. For a non-UK resident who needs flexible, ongoing access to their pension from abroad, it is not.
Flexible Access Is Not Available to Non-UK Residents on ReAssure
This is the central issue that non-UK residents holding ReAssure pensions face, and it is worth stating plainly. If you have a ReAssure pension and you require flexible access as a non-UK resident, you will need to transfer out of the scheme. ReAssure does not support flexible drawdown for non-UK residents.
Flexible drawdown, formally known as flexi-access drawdown since the 2015 pension freedoms reforms, is the mechanism that allows pension holders to take income as they need it, in any amount, while keeping the rest of the pot invested. Background on the framework is available in the HMRC Pensions Tax Manual. It is the standard and most tax-efficient way for a non-UK resident to access a UK pension in retirement, because it allows withdrawals to be timed and sized around the relevant double taxation agreement, the client's income position in their country of residence, and NT tax code treatment at HMRC.
Without flexi-access drawdown, the practical options for a ReAssure pension holder living abroad are deeply unattractive. An annuity, a guaranteed income for life purchased from an insurer, is rarely available to non-UK residents through UK pension schemes, and when it is, the lack of currency flexibility makes it poorly suited to someone whose living costs are in Australian dollars, US dollars, UAE dirhams, or any currency other than sterling. That leaves full encashment: taking the entire pension pot as a lump sum.
The Full Encashment Problem: A Tax Trap for Non-UK Residents
Full encashment of a pension is the most tax-inefficient way to access UK pension savings for a non-UK resident. It crystallises the entire pot in a single tax year, concentrating all the taxable income into one event. The consequences depend on the double taxation agreement between the UK and the client's country of residence, but in most cases, they are severe.
Under UK rules, up to 25% of the pension can be taken as a pension commencement lump sum free of UK income tax, subject to the Lump Sum Allowance of £268,275 as set out in GOV.UK guidance on the Lump Sum Allowance. The remaining 75% is taxable as UK income. Without a properly applied NT tax code, which requires the pension to have been crystallised first, the full 75% is likely to be subject to UK emergency tax deduction at source, requiring a subsequent reclaim from HMRC.
In the country of residence, the position is typically worse. Most countries do not recognise the UK's 25% tax-free treatment. From a local tax perspective, the entire encashment, including the portion the UK treats as tax-free, may be treated as ordinary taxable income. For a pension pot of GBP 200,000, this can mean a local tax bill of 30%, 40%, or more on the full amount in a single year. Avoiding this outcome through phased flexi-access drawdown, spread across multiple years to stay within lower tax brackets, is exactly the kind of planning that ReAssure's model makes impossible for non-UK residents.
Non-UK residents who encash a ReAssure pension in full without planning can face combined UK and local tax charges that consume a substantial proportion of a pension built up over decades. A transfer to an International SIPP before accessing the pension is almost always the correct approach.
ReAssure Customer Service Adds a Further Complication
ReAssure's customer service record has been the subject of extensive client complaints, and non-UK residents experience this acutely. Obtaining a current valuation, requesting transfer documentation, processing Letters of Authority for an overseas adviser, and handling international correspondence all involve the friction that comes with a large legacy administrator whose systems and processes were not designed with an internationally mobile client base in mind.
ReAssure's own documentation is explicit that it is not authorised to provide advice or make personal recommendations. It can only provide factual information. This means that when a non-UK resident contacts ReAssure to understand their options, they are told what the policy terms allow, which, for overseas residents, typically means very little, without any guidance on what they should do or why. The combination of restricted access and limited guidance creates a situation where clients are stuck, uninformed, and have no internal support to resolve the problem.
For non-UK residents trying to initiate a transfer to an International SIPP, the process of extracting pension documentation from ReAssure and processing the transfer discharge can be slower and more administratively burdensome than equivalent transfers from modern platforms. Cameron James has direct experience of this process and manages it on behalf of clients, handling the correspondence and paperwork to ensure the transfer proceeds without the client needing to navigate ReAssure's systems independently.
Investment Choice Within ReAssure: Frozen in the Past
Beyond the access restrictions, the investment options within ReAssure's legacy policies are a further reason why non-UK residents are poorly served by remaining in the scheme. Most ReAssure policies offer a limited selection of with-profits funds, managed funds, and in some cases a small number of unit-linked options. These reflect the product designs of the era in which they were originally written.
For a non-UK resident whose investment strategy needs to reflect their cross-border tax position, their currency exposure, and their retirement income objectives in a country outside the UK, a legacy insurer's restricted fund range is genuinely inadequate. The ability to hold globally diversified ETFs and funds, adjust allocation as retirement approaches, and manage currency exposure within the pension are features that simply do not exist within the ReAssure framework.
Staying in a ReAssure policy is not a neutral decision. It is an active choice to leave pension savings in a product that cannot serve the holder's needs as a non-UK resident, managed by a provider that cannot advise them, paying into a currency they may not use, and structured around a retirement model that ceased to reflect best practice in 2015.
The Position for US Persons Holding a ReAssure Pension
For US citizens, green card holders, and US tax residents, a ReAssure pension creates a particular set of problems. ReAssure does not have the infrastructure to assist US persons with cross-border reporting obligations.
FBAR reporting, Form 8938 disclosures, and the management of US income tax on UK pension distributions under the US-UK Double Taxation Agreement all require a depth of engagement that a closed book legacy insurer cannot provide. The treatment of the 25% pension commencement lump sum is a specific concern. The UK does not tax it. The United States treats it as ordinary income in the absence of a foreign tax credit, since no UK tax was paid on it to credit against the US liability. For a US person sitting on a ReAssure pension and approaching retirement, taking the lump sum without proper planning around the US tax position can result in a significant and avoidable US tax bill. This is a planning decision that must be made before any crystallisation event, in conjunction with the client's US tax adviser and a UK cross-border pensions specialist.
The annual FBAR reporting obligation on foreign financial accounts with aggregate values above USD 10,000 applies to UK pensions held by US persons.
Form 8938 thresholds may also apply; see the IRS Form 8938 page. A US person holding a ReAssure pension who is not reporting it correctly as part of their annual US tax filing is carrying a compliance risk that has nothing to do with the pension itself and everything to do with the reporting framework around it.
Why a Transfer Is the Right Answer for Most Non-UK Residents
There are cases where remaining in an existing pension is the right decision, where the pension holds valuable protected tax-free cash rights above the standard 25%, where specific investment guarantees are attached that would be lost on transfer, or where the overall value is small and the cost of transferring outweighs the benefit of access flexibility.
For ReAssure pensions held by non-UK residents, these considerations need to be assessed carefully before proceeding. Protected tax-free cash is worth preserving where it exists, and a transfer suitability assessment conducted by a qualified cross-border adviser should include a review of any enhanced protections attached to the policy before a transfer recommendation is made.
In the majority of cases involving non-UK residents and ReAssure legacy pensions, however, the conclusion is that the inability to access the pension flexibly from abroad, combined with the restricted investment universe, the currency inflexibility, and the inadequate servicing model for non-UK resident clients, means that a transfer to an International SIPP is in the client's best interests. The question is not usually whether to transfer but when, and the answer is typically before retirement, so that the transfer can be completed and the pension properly structured before any crystallisation event.
What Is an International SIPP?
An International SIPP is a UK Self-Invested Personal Pension that is specifically structured and administered for people who live outside the United Kingdom. It is not a different type of pension in legal or regulatory terms. It is a standard UK registered pension scheme, regulated by the Financial Conduct Authority, recognised by HMRC, and carrying the same tax-efficient pension wrapper as a SIPP held by a UK resident.
The distinction lies in how it is set up and who services it. A mainstream UK SIPP, the kind offered by legacy insurance providers and consumer platforms, is designed for clients who live in the UK, hold UK bank accounts, are advised by UK-authorised advisers, and are taxed under UK rules alone. When those conditions no longer apply, the standard SIPP model breaks down in ways that range from inconvenient to genuinely damaging.
An International SIPP is administered by a trustee and platform that is set up to accept clients regardless of where they live. It can pay income and lump sums to bank accounts in any country and any currency. It is serviced by advisers who hold the regulatory authorisations relevant to the client's country of residence. And it is managed with direct reference to the client's cross-border tax position, not simply to UK pension rules in isolation.
In short, the pension itself does not change. What changes is the infrastructure around it, making it appropriate for life outside the UK rather than transplanting a domestic product into an international context where it does not fit.
Transferring an existing UK pension into an International SIPP is a domestic UK pension transfer. Both the existing scheme and the receiving scheme are UK-registered, so no Overseas Transfer Charge applies, and there is no tax event on the transfer itself. The pension's accumulated value moves intact into the new structure.
Key Features of an International SIPP
The following features distinguish an International SIPP from a legacy UK pension and explain why they matter for non-UK residents.
- Payment to overseas bank accounts in local currency, removing the need to maintain a UK bank account purely to receive pension income.
- Full flexi-access drawdown for non-UK residents, allowing income to be taken in any amount and at any frequency, rather than forcing a full encashment or restricting access to a lump sum only.
- NT (nil tax) code processing for drawdown, meaning HMRC can authorise pension payments without UK tax deducted at source where a double taxation agreement provides for this.
- Adviser-led structure with cross-border authorisations, ensuring that the advice relationship is properly constituted in the client's country of residence.
- Wide investment universe, typically encompassing globally diversified ETFs, funds, investment trusts, and other asset classes, not a closed or restricted fund range from a legacy insurer.
- Multi-jurisdictional administration experience, covering the reporting, compliance, and documentation requirements that arise when a UK pension intersects with the tax rules of another country.
- UK regulatory protections intact, including FCA oversight of the scheme and FSCS protection where applicable.
For US-connected clients specifically, the International SIPP framework also supports the dual-compliance requirements that arise under US tax law. Investments within the SIPP wrapper are not subject to PFIC reporting requirements during accumulation. Drawdown can be structured with reference to the US-UK Double Taxation Agreement, including the correct application of Article 17 provisions and the treatment of the 25% pension commencement lump sum under US income tax rules. Annual FBAR and Form 8938 reporting obligations are managed as part of the advisory relationship.
What This Means for Non-UK Residents Holding a ReAssure Pension
If you are a non-UK resident with a ReAssure pension, you are facing a structural mismatch between the product you hold and the life you actually live. The pension itself may have been entirely appropriate when it was originally written. It is the combination of your current country of residence, your retirement income needs, and ReAssure's legacy servicing model that has created the problem, and that problem will not resolve itself by waiting.
Practically, this means that the longer you leave the situation unaddressed, the closer you get to a forced decision at retirement. By the time you reach the point of needing income from the pension, your options on the ReAssure platform will be limited to those Jonathan has described above: full encashment with all the tax consequences that brings, or an annuity that may not be available to you in any case. Acting in advance of that point, while the pension is still in accumulation, gives you the planning flexibility to structure the transfer properly and to be set up for tax-efficient drawdown when the time comes.
A Cameron James adviser will review your ReAssure pension alongside any other UK pension or investment arrangements you hold, identify whether there are any protected rights worth preserving, and set out the route to an International SIPP structure that fits your country of residence and your retirement objectives.
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JONATHAN LAWS — SENIOR IFA, CAMERON JAMES
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“In ten years of advising clients on UK pensions held abroad, the ReAssure situation is one of the most consistently frustrating I see. The clients are usually doing everything right. They have built up a pension over a career, they have moved abroad for work or retirement, and they assume their UK pension will simply work for them when they need it. Then they discover that it cannot, because the policy is sitting with a closed book insurer that has no path to flexi-access drawdown for non-UK residents. The good news is that this is a fixable problem. A transfer to an International SIPP, properly advised and properly structured, gives you back the flexibility and tax efficiency that the pension was always supposed to deliver. The point is to do it before retirement, not when you are already at the point of needing income.”
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Frequently Asked Questions
You can technically keep a ReAssure pension while living abroad, but you will face significant restrictions on how you can access it. ReAssure does not support flexi-access drawdown for non-UK residents, which means your options at retirement are typically limited to full encashment or, where available, annuity purchase. For most non-UK residents, these options are tax-inefficient, currency-inappropriate, or simply not practical. A transfer to an International SIPP before retirement is usually the right course.
No. A transfer from a UK-registered pension, such as a ReAssure policy to another UK-registered pension scheme, including an International SIPP, is a tax-neutral event in the UK. It is not a benefit crystallisation event, it does not trigger income tax, and it is not subject to the Overseas Transfer Charge, which applies only to QROPS transfers. Your pension's accumulated value moves intact into the new structure. The tax treatment in your country of residence should still be confirmed with a local tax adviser.
Flexi-access drawdown is the mechanism that allows you to draw income from your pension in any amount and at any frequency while keeping the rest invested. It matters for non-UK residents because it allows withdrawals to be timed and sized around the relevant double taxation agreement, your local income position, and the application of an NT tax code at HMRC. Without flexi-access drawdown, your only practical option is full encashment, which crystallises the entire pension in a single tax year and is almost always tax-inefficient.
An NT (nil tax) code is a code issued by HMRC that authorises a UK pension provider to pay your pension income without deducting UK income tax at source. It applies where a double taxation agreement between the UK and your country of residence gives the right to tax that pension income to your country of residence, not the UK. The pension must be crystallised, and an NT code must be in place, before tax-efficient drawdown to a non-UK resident can begin. An International SIPP provider is set up to handle this process; ReAssure typically is not.
Full encashment concentrates all of your taxable pension income into a single tax year. Even with the 25% UK tax-free element applied, the remaining 75% is taxable, often subject to UK emergency tax at source. In your country of residence, the entire encashment, including the UK tax-free portion, may be treated as ordinary taxable income, since most countries do not recognise the UK's 25% tax-free treatment. The result is typically combined UK and local tax charges that consume a substantial proportion of the pension. Phased flexi-access drawdown across multiple years avoids this concentration.
An International SIPP is a UK SIPP. It is a UK-registered pension scheme regulated by the FCA and recognised by HMRC, carrying the same tax-efficient pension wrapper. The difference is in how it is set up and serviced. An International SIPP is administered to accept clients regardless of where they live, pay income to overseas bank accounts in local currency, support NT code drawdown, and work alongside advisers authorised in the client's country of residence. It is the infrastructure around the pension that changes, not the pension itself.
No. The Overseas Transfer Charge applies to transfers to a Qualifying Recognised Overseas Pension Scheme (QROPS), which are pensions held outside the UK. An International SIPP is a UK-registered pension, so a transfer from one UK pension (such as a ReAssure policy) to an International SIPP is a domestic UK transfer. No Overseas Transfer Charge applies. The Overseas Transfer Allowance only becomes relevant if a transfer to a QROPS is being considered, which is a different planning decision.
ReAssure transfers typically take longer than transfers from modern platforms, often six to twelve weeks once paperwork has been submitted, depending on the policy type and complexity. ReAssure's processes can be slow and administratively burdensome, particularly for non-UK residents. Cameron James manages the transfer end-to-end, including Letters of Authority, discharge paperwork, NT tax code applications, and onboarding with the receiving International SIPP provider. You do not need to navigate ReAssure's systems independently.
Speak to a Cameron James Adviser About Your ReAssure Pension
If you hold a ReAssure pension and you have moved outside the UK, the structural restrictions on your access to that pension will not resolve themselves. Acting in advance of retirement, while the pension is still in accumulation, gives you the planning flexibility to transfer to an International SIPP and be properly set up for tax-efficient drawdown when the time comes. A Cameron James adviser will review your full pension and wealth position, identify any protected rights worth preserving, and set out a clear plan.
Book a call with a Cameron James adviser today
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DISCLAIMER
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This article is for informational purposes only and does not constitute financial, tax, or legal advice. Always consult a qualified and regulated financial adviser before making any decisions about your pension or financial planning arrangements. Tax laws are complex and vary by individual circumstance. Cameron James does not offer tax advice.
This post is not targeted at UK Residents, and has no connection to any FCA authorised advice or advice firm.
ReAssure information referenced in this article is drawn from publicly available regulatory and corporate sources, including the FCA Register, accessed at the time of writing. ReAssure Limited is authorised by the Prudential Regulation Authority and regulated by the PRA and Financial Conduct Authority (FCA firm reference number 110495) and forms part of Standard Life plc. Product and service terms are subject to change, and clients should refer to ReAssure directly for the current terms applicable to their specific policy.
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