Can I transfer my UK pension to Poland?

For Brits living in Poland (or Poles who have returned home after living in the UK), one of the big questions involves what to do with any pension schemes that they have accumulated in Britain.

This issue has become even more pertinent in the aftermath of Brexit and the additional uncertainty that it has brought to the table.

Firstly, unfortunately, the answer to the question of whether you can transfer your UK pension to a scheme in Poland, is, no you can’t.

However, this does not end your options. For anyone who is resident in Poland and has a UK pension, there are other potential courses of action open to you.

Option 1 – Transfer Your Pension to an International SIPP

A SIPP (Self Invested Personal Pension) is a pension scheme that is established under trust in the UK.

It allows you to accept the cash equivalent transfer value (CETV) from a defined benefit scheme or the funds from a defined contribution scheme.

Some of the benefits of transferring your pension to such a structure are as follows:

It is covered by the UK Poland double taxation treaty. This means that you can be sure that your 25% pension commencement lump sum (PCLS) will be tax free;
You have flexibility in terms of how your pension is invested;
You have the option to hold your pension in a currency that is more closely matched to your future expenses and liabilities (e.g. EUR);
You have flexibility in terms of how pension income and lump sums are withdrawn (from minimum pension age of 55);
You potentially have greater flexibility to decide who will be nominated as beneficiaries under your pension.

Option 2 – Do nothing

That’s right, leave your pension where it is.

Although it would still be worth reviewing the investments within your pension to make sure that they are in line with your objectives and risk profile.

Certainly, if your pension is a defined benefit/final salary scheme, there may be very good reasons for leaving it where it is.

At the very least, you should be fully aware of the benefits available through your current scheme before considering giving them up.

I recently heard from a client in Poland that his UK pension provider was refusing to let him take his tax-free lump-sum because of Brexit.

This is absolute nonsense on the part of the pension company.

If your pension provider says the same, find another one.

Option 3 – Qualifying Recognized Overseas Pension Scheme (QROPS)

Up until November 2021, a QROPS would have been an option for Polish residents and would have certainly have been worth considering for anyone approaching the UK pension Lifetime Allowance.

However, due to new rules introduced by the UK government, this is no longer a viable option.

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QROPS tax treatment in Poland

If you are resident in Poland and already have a QROPS, it is vitally important that you understand the implications of any double taxation treaty between Poland and the country in which your QROPS is located.

In some cases it will be much less favorable than the treaty between the UK and Poland.

Conclusion

At the end of the day, what you do with your UK pension as a resident of Poland will be dependent upon your individual circumstances and specific financial plans.

As always, it is vital to be fully aware of exactly what you have before making any decisions.