There is No Such Thing as an International SIPP it is Con

To be quite honest, we are a little tired of seeing overseas ‘Expat’ financial advisers promoting UK pension transfers and International Self Invested Personal Pensions (International SIPP).

There is no such thing as an International SIPP. 

• A SIPP is simply a personal pension plan (PPP) that uses UK HMRC laws on permitted pension fund investments to invest in a wide range of ‘worldwide’ permissible assets (HMRC rules) through pension company funds, offshore bonds, direct share holdings in stock markets, physical commercial property, bank accounts, precious metals and can even lend people money.  The clue is in the title, it is a personal pension plan in the UK, approved by HMRC, that gives you the power of self investment i.e., you or your adviser choose where to invest and not a fund manager – a Self Invested Personal Pension (SIPP).  Your SIPP could even buy an office or shop in Timbuctoo to rent out if you wanted to.
• An 'International' SIPP is simply a UK authorised and regulated pension plan.  'International' is just a branding/title con as all UK SIPPs can invest worldwide.

Are Expat Advisers Breaking FCA Rules?

• Expat financial advisers based outside the UK cannot legally promote UK pension transfers into a UK ‘International’ SIPP or any other UK regulated product unless either they or another firm (that they deal through) has a branch/is based in the UK and authorised by the FCA in the UK.  Even a simple page on an expat website mentioning International SIPPs is a financial promotion of a UK regulated product and should be ‘signed off’ by a UK authorised firm.
• Your expat financial adviser can talk to you about your UK pensions, but they cannot ‘recommend’ a specific UK regulated product.  Even just mentioning an 'International' SIPP as a potential solution for you is a personal recommendation  to you and a regulated activity in the UK, so they must be authorised in the UK to promote this product to you.

The ‘International’ SIPP is a Con and a Double Fee for the Expat Adviser

• Expat advisers promote ‘International’ SIPPs (even though there is no such thing, it is simply a title on a brochure), but it will be a UK SIPP and it must be processed/advised on by a UK firm.
• The SIPP is established and monies transferred in.
• Your expat adviser will usually be paid an introductory fee or commission for this.
• As your SIPP can invest in worldwide permitted investments, usually an Offshore Investment Bond e.g.  in the Isle of Man or Dublin will be recommended. 
• Note, it is an Offshore Bond, meaning the investment product inside the SIPP is now outside the UK and outside the UK FCA's jurisdiction.
• Your expat adviser will usually be paid another fee/commission on the Offshore Bond.
• This is likely to be the second fee they have been paid for the same overall transaction.
• As the commission/fee is for a non-UK regulated investment for a non-UK adviser, there may be no requirement to disclose fees or commissions paid to them, unlike the UK where UK advisers must disclose/agree fees before proceeding.
• As the Offshore Bond is outside the UK, your expat adviser will be free to offer fund/investment advice for the bond.

We have seen too many cases where British Expats are ‘conned’ into having an 'International' SIPP with an Offshore Bond inside it, meaning the expat adviser may have been paid at least twice (for the SIPP and then the Bond) and may not have even disclosed what they have been paid.  A recent expat living overseas approached us after they had been advised overseas on a UK defined benefit pension and subsequently transferred c£500,000 to a UK 'International' SIPP (UK adviser working with an expat adviser) and then inside the SIPP the expat adviser had invested all the pension monies into an offshore bond in the Isle of Man and when the client looked to cancel the offshore Isle of Man investment and invest in UK funds, was also dismayed to learn of £45,000 in exit penalties.  Wonder where that £45,000 penalty came from?  Were huge commissions paid to the expat adviser?  Of course they were (and they need recovering if you cancel early).

See/Watch Expat Commission Pirates Expat Pirates

We Are UK Based Expat Advisers

We are UK authorised and regulated independent financial advisers that deal with British expats and non-UK citizens all over the world in connection with UK  pensions, investments and taxation interests only. 

We have permission from the FCA to do so and we are fully insured for worldwide activities in addition, when dealing with expats, the FCA requires us to check with your ‘in country’ regulator to ensure we are not breaching any rules there.

If You Live Outside UK Please Note:

We are a UK registered business, authorised and regulated by the Financial Conduct Authority in the United Kingdom.  We are fully insured for advice that we give from the UK to clients all over the world.   That said, we are not authorised outside the United Kingdom and as such, new products and services are usually only available for UK residents.  We are also no longer authorised in the European Union under financial services ‘passporting’ given Brexit.

That said, there are many British Expats and Foreign Nationals living all over the world that have existing pensions, investments, financial or tax interests in the UK.  Your local adviser, where you live, is unlikely to be authorised in the UK meaning they cannot advise on your existing UK interests and likewise, we are not authorised to give advice on new pensions and investments where you live.

EU Residents

The Brexit Trade Agreement did not include financial services passporting although it was supposed to.   Negotiations are ongoing with regard to ‘Equivalency’ on financial services with 5 X Memorandums of Understanding (MOUs) agreed in January 2021.  MOUs are essentially agreements to reach an agreement only.  One of the MOUs between UK and EU regulators confirms that they are working towards ‘delegated authority’ where if an EU resident has a UK pension/investment, then respective EU advisers are not authorised to advice on unless they have set up a UK branch with FCA authorisation in UK and therefore advice will need to be delivered by a UK authorised IFA.  This is where EU regulators delegate their authority to the UK FCA to oversee and regulate the advice on a UK pension/investment.

Given the ‘state of flux’ we are all in as negotiations continue, technically, we are no longer authorised in EU (for the time being).  Fish, wine, cheese, and cars are no problem, but finance is a ‘no’ at present.  We do not ‘solicit’ or promote services to EU residents, but we will accept ‘Reverse Solicitation’ i.e.  you approach us to help you with existing UK taxes, investments, or pensions only.  We will not advise on or arrange 'new money' investments for you, but we will advise on existing UK arrangements that are then actioned/transferred/amended within the UK.  Given this, and until an agreement is reached on Equivalency and Delegated Authority, we will offer the technical advice from the UK on your UK pensions, investments, and tax with our requirement that you also take advice locally in the EU to oversee any actions at 'your end' to ensure tax compliance and reporting requirements with EU authorities.  You should also be aware that there are even greater restrictions for residents of France.  No Fishing = No Finance in France, although they are softening their position to that of other EU authorities where things appear to continue as they were with EU regulators happy that the FCA oversees any UK advice on existing UK products and services.

Please note we have written confirmation from both our professional insurers and the FCA that all advice that we offer must be offered and delivered from the UK, under FCA regulatory rules and FCA protection and that we are permitted to advise people anywhere in the World according to the UK regulator, but we must check if there any regulatory restrictions where a client lives.  In short, we offer advice as if you were resident in the UK and if you and your EU adviser check with your EU regulator that they are happy for us to continue UK advice for you in tandem with your local adviser ensuring tax compliance and reporting requirements with EU authorities.  We will require this in writing from your EU regulator/your EU adviser.

Resident Outside Europe

As we are not authorised where you live and your local advisers are unlikely to be authorised in the UK, we operate a similar option to EU residents with 'Reverse Solicitation'.  We do not ‘solicit’ or promote financial services to non-UK residents, but we will accept ‘Reverse Solicitation’ i.e.  you approached us to help you with existing UK taxes, investments, or pensions only.  We will not advise on or arrange 'new/additional money' investments for you, but we will advise on existing UK arrangements that are then actioned/transferred/amended within the UK.  Given this, we will offer the technical advice from the UK on your UK pensions, investments, and tax with our requirement that you also take advice locally in the country that you live to oversee any actions at 'your end' and ensure tax compliance and reporting requirements with your local finance and tax authorities.

Please note we have written confirmation from both our professional insurers and the FCA that all advice that we offer to expats must be offered and delivered from the UK, under FCA regulatory rules and FCA protection and that we are permitted to advise people anywhere in the World according to the UK regulator, but we must check if there any regulatory restrictions where a client lives.  In short, we offer advice as if you were resident in the UK and provided you and your local adviser check with your resident country's regulator that they are happy for us to continue UK advice for you in tandem with your local adviser ensuring tax compliance and reporting requirements with your resident country's authorities.  We will require this in writing from your country's regulator/your local adviser.

Expat Permissions

We already have permissions from as far away as the SEC in the USA, Australia, Canada, NZ, Japan, etc., even the Ascension Islands would you believe?  We also have permissions within the EEA from Ireland, Germany, Greece, Hungary, Spain, and Switzerland.  France is a partial “yes” at present with restrictions and for other countries not yet mentioned, we deal on a case-by-case basis, when expats approach us from other countries, we will contact each local regulator to seek permission/ensure no local rules are broken.  Most overseas regulators say: “No problem, it has nothing to do with us and is outside our jurisdiction” but just one, Finland gave us a categoric “No, you must set up a branch here”.  That said, we will still require expat clients to take local advice on top of anything we do in the UK (if anything).

All advice is offered from the United Kingdom with the explicit agreement and understanding that any fee for services will be disclosed before proceeding and is offered under the laws of England and Wales, and the UK Courts shall have exclusive jurisdiction and no other country’s regulatory or legal systems have any judicial powers over any dealings between us and expat clients.

Never forget, there is no such thing as an international SIPP, it is SIPP and beware of the SIPP/Offshore Bond double fee/commission trap. 

• If your expat adviser does not disclose all fees and commissions that will be paid to them before you start, then we suggest you should walk away. 
• That said, there will be some expat advisers that are trustworthy and do the job properly, for example we have dealt with a number of advisers in many countries that have referred clients to us and done the job properly and in the best interests of their client when it comes to UK pensions transfers, SIPPs and flexible drawdown.

Contact  Call Back  Calculators  Our Fees