QNUPS Pension Review for Expats: Is Your Offshore Pension Still Outside UK Inheritance Tax?

Technical note: This article reflects UK pension, QNUPS and inheritance tax rules as at May 2026. QNUPS, tax residency, long-term residence, inheritance tax, overseas pension rules and beneficiary treatment are complex. The correct position depends on the member’s residence history, scheme jurisdiction, scheme status, contribution history, beneficiaries and future retirement plans. Personal tax and pension advice should be taken before making any decision to retain, restructure, contribute to, draw from or unwind a QNUPS.

Direct answer

If you set up a QNUPS years ago, it may have been done for perfectly sensible reasons at the time. Many expats used these structures because they were living outside the UK, building wealth internationally, and wanted a pension arrangement that could support retirement planning, estate planning, and family protection on a more global scale.

The issue is not that QNUPS are suddenly wrong. The issue is that the rules around UK inheritance tax have changed.

From 6 April 2027, qualifying non-UK pension schemes are brought into the pension inheritance tax framework for UK long-term residents, subject to the detailed rules. For UK long-term non-residents with international pension schemes, the situation may differ.

So the question is not simply, “Do I have a QNUPS?” The better question is, “Does this structure still work for my residence position, my family, my retirement plan and the rules that now apply?”

A comprehensive QNUPS review should give you clarity. It should tell you what still works, what needs updating, what should be left alone and what may need deeper advice before the 2027 pension inheritance tax changes take effect.

Why are old Expat QNUPS pensions worth reviewing now?

Many UK-connected expats were advised years ago to use QNUPS as part of offshore pension, inheritance tax or retirement planning. In many cases, the thinking was straightforward. The client had left the UK, was building wealth overseas, and wanted a structure that could support long-term retirement provision, investment choice, family planning and international flexibility.

That may have made sense at the time.

The challenge is that cross-border planning does not stand still. Tax rules change. Residence rules change. Families change. Retirement plans change. A structure that was suitable when it was created may still need to be reviewed as the world around it changes.

From 6 April 2025, the UK moved away from the old domicile and deemed domicile framework for inheritance tax and introduced a long-term residence test. Under the new regime, long-term UK residents may have non-UK assets brought within the UK inheritance tax net.

The pension inheritance tax position is also changing. From 6 April 2027, most unused pension funds and pension death benefits are brought within the value of a deceased person’s estate for inheritance tax purposes. Crucially for QNUPS holders, the rules refer not only to UK-registered pension schemes, but also to qualifying non-UK pension schemes and section 615 schemes, subject to residence status and the detailed rules.

A Section 615 pension (formally Section 615(6) of the UK Income and Corporation Taxes Act 1988) was an HMRC-approved UK retirement scheme specifically designed for employees who worked wholly outside the UK. It allowed companies to provide tax-efficient pension benefits to internationally mobile workers.

The point is not to look back and criticise the original decision. The point is to make sure an old structure still works for the life you are living now.

Who should read this?

This article is especially relevant if you are a UK-connected expat who established a QNUPS years ago, were advised that your offshore pension could help with inheritance tax planning, have not reviewed the structure since the UK tax rules changed, may return to the UK, have UK resident beneficiaries, or are unsure whether the scheme was created mainly for retirement planning or estate planning.

It is also relevant if you live overseas and believe your offshore pension is automatically outside the UK inheritance tax system.

For many expats, the issue is not that the QNUPS were necessarily unsuitable when they were established. The issue is that the rules, family position, residence position and available planning alternatives may have changed since then.

You should review a QNUPS if…

You should review a QNUPS if it was created before the 2025 long term residence rules, if it was mainly recommended for inheritance tax planning, if you may still be inside the UK IHT tail, if your beneficiaries live in the UK, if you may retire in the UK or Europe, if the charges feel high, if the investments have not been benchmarked, if the original adviser is no longer involved, or if you cannot clearly explain why the structure still exists.

That last point is important. If you know you have a QNUPS but cannot clearly explain what it does for you today, the structure deserves a proper review.

What is a QNUPS in plain English?

A QNUPS is a qualifying non-UK pension scheme.

That sounds technical because it is. In simple terms, it is an overseas pension scheme that meets specific UK rules for inheritance tax purposes. It is not a UK-registered pension scheme. It may not operate like a UK workplace pension or SIPP. Different QNUPS can be structured in different ways depending on the jurisdiction, trustee, administrator, and scheme rules.

HMRC guidance states that a qualifying non-UK pension scheme is entitled to the same inheritance tax treatment as a registered pension scheme, but also makes clear that it will not necessarily provide similar pension benefits or be structured in a similar way. A QNUPS is broadly a pension scheme that is not a UK-registered pension scheme, is established outside the UK, and meets the relevant qualifying requirements.

This is why QNUPS can be misunderstood. The word “pension” can make people assume they are dealing with something familiar. In reality, a QNUPS may have very different rules, costs, access terms, tax treatment, reporting and beneficiary procedures.

A QNUPS is not simply another type of QROPS

A QROPS is usually relevant when UK-registered pension benefits have been transferred to an overseas pension scheme that meets HMRC-recognised requirements for overseas pension schemes. A QNUPS is broader. It is a qualifying non-UK pension scheme for inheritance tax purposes, and it may have been funded with cash, investments, or other wealth that was never held in a UK-registered pension.

Some overseas schemes may be both QROPS and QNUPS. Some may be QNUPS only. Some clients may use the terms loosely because they were told years ago that they had an “offshore pension”.

That is not good enough for a holistic review.

Before any advice can be given, the first task is to identify exactly what the structure is. Is it a QNUPS, a QROPS, both, a former recognised overseas pension scheme, a local international pension arrangement, or something else entirely? The answer can affect transfer rules, inheritance tax treatment, access, income tax, reporting, scheme regulation and whether any UK tax charges could apply.

A QNUPS is not just “another offshore pension”. It is a specific type of structure, and the label needs to be verified before the planning conclusions can be trusted.

Many QNUPS holders know the label, but not the full story

Many expats know they have a QNUPS, but they no longer know exactly why it was set up in the first place. That is more common than people think.

These structures are often created at busy moments in life, perhaps after leaving the UK, building a career overseas, selling a business, restructuring wealth or trying to protect family assets. At the time, the client may have relied heavily on professional advice and reasonably assumed the structure would continue doing what it was designed to do.

Years later, the paperwork still exists, the provider still sends statements, and the structure carries on in the background. But the client may not know what fees are being charged, where the scheme is legally established, whether the original tax rationale still applies, how benefits can be drawn, what assets are held inside it, or how death benefits would actually be administered for the family.

“Risk comes from not knowing what you’re doing.” - Warren Buffett

That is a useful way to think about old QNUPS structures. The risk is not simply that a client has an offshore pension. The risk is that the structure is being trusted on assumptions that may no longer have been tested.

The assumption may be that the QNUPS remain outside UK inheritance tax. It may be that the assets are still suitable. It may be that the costs remain justified. It may be that the beneficiaries will receive the pension smoothly. It may be that living outside the UK automatically means the client is outside the UK tax net.

Each of those assumptions may still be correct. But each should be checked.

A QNUPS review is not about undoing the past. It is about distinguishing what remains true from what may have changed, so the structure can either be kept with confidence or adjusted before it becomes a problem.

Why QNUPS became attractive to expats and high-net-worth families

QNUPS became attractive because they appeared to offer a pension-style structure for people whose lives, assets and retirement plans were no longer centred entirely on the UK.

For some clients, the appeal was international flexibility. A QNUPS could be established outside the UK, hold a wider range of assets depending on the scheme rules, and potentially support retirement planning in a way that feels more aligned with an overseas lifestyle. For clients who had already used UK-registered pension allowances, had no UK-relevant earnings, or did not benefit from further UK pension tax relief, a QNUPS was sometimes offered as an alternative long-term retirement-planning structure.

For others, the appeal was inheritance tax planning. Under the old framework, QNUPS were often discussed because they could receive pension-style inheritance tax treatment while being established outside the UK.

The planning logic was often easy to understand. A client had left the UK, had accumulated offshore wealth, wanted to build long-term retirement provision, and also wanted to pass wealth efficiently to family. A QNUPS could appear to sit at the intersection of retirement, investment, and estate planning.

But that does not mean every QNUPS is suitable. It also does not mean every QNUPS remains suitable now.

A pension structure that was created for one tax world may need to be reviewed when that tax world changes.

Was the QNUPS genuinely created for retirement planning?

This is one of the most important questions.

A QNUPS may have inheritance tax consequences, but it should still be a pension structure. It should not simply be an offshore estate planning wrapper wearing a pension label.

A proper review should look at why the QNUPS was created, how it was funded, what retirement income it was intended to provide, what access rules apply, whether withdrawals have ever been taken, and whether the level of contributions made sense for the client’s age, wealth, lifestyle and retirement needs at the time.

This matters because some QNUPS were funded with substantial wealth. That does not automatically make the planning wrong. But the funding history needs to be defensible for pension planning. Large contributions made late in life, or contributions that look more like estate planning than retirement provision, may need specialist tax review.

The test is not only whether the QNUPS exists. It is whether it genuinely looks and behaves like retirement planning. That is a different question from whether it was tax-efficient at the time it was established.

Contributions need to be understood, not just the current value

A QNUPS review should not only look at the current balance.

• It should also examine how the structure was funded.

• Were contributions made from cash?

• Were investment assets transferred?

• Were contributions made regularly over time, or was there a single large contribution? How old was the member when the contributions were made?

• Was the contribution level proportionate to the retirement objective?

• Was there a clear retirement income plan?

This is where QNUPS are different from many ordinary pensions. A UK-registered pension contribution usually comes with strict UK tax relief rules, contribution limits and pension legislation around annual allowances. A QNUPS may not have been used for UK tax relief in the same way. In many cases, its appeal was not an upfront UK tax-relief benefit but rather the offshore pension framework, investment flexibility and inheritance tax treatment.

That makes the funding history extremely important.

If the original documentation clearly shows a genuine retirement-planning purpose, it supports the structure. If the documentation is vague, the member was already elderly, or the contribution appears mainly designed to remove assets from the estate, the position may need deeper review.

Why the QNUPS case has narrowed

The QNUPS case has narrowed because the world around these structures has changed.

The UK inheritance tax framework has moved from domicile to long-term residence. Pension death benefits are being brought into the inheritance tax conversation from 2027. Modern UK pensions and international SIPP structures have also become more flexible than many older UK arrangements were when QNUPS planning first became popular.

Costs matter too. QNUPS can involve trustee fees, administration fees, investment platform charges, fund costs, discretionary fund manager charges, adviser fees, dealing costs, currency costs and exit charges. A QNUPS does not need to be wrong to become poor value. It may simply have become too expensive for the planning benefit it still provides.

The client’s life may also have changed. They may be closer to retirement. Their beneficiaries may now live in the UK. Their retirement country may have shifted. Their estate planning may be more UK-connected than it was when the QNUPS were created. The adviser who arranged the structure may no longer be actively reviewing it.

That is why “it was suitable then” is not enough. The structure has to be suitable now.

UK long-term residence is now the key question

The central question for many QNUPS holders is now residence.

Before April 2025, many QNUPS planning conversations were framed around domicile. From April 2025, the UK began using long-term residence for inheritance tax purposes. A person may be a long-term UK resident if they have been a UK resident for the previous 10 consecutive years, or for at least 10 out of the previous 20 tax years.

This is particularly important for expats in Dubai, Abu Dhabi, Riyadh, Doha and elsewhere in the world. A person can be non-resident for UK income tax purposes but still relevant for UK inheritance tax under the long-term residence rules or the post-departure tail.

A British executive who lived in the UK for decades and left in 2024 may feel fully overseas. They may have no UK salary and no intention to return immediately. But if they remain within the long-term residence test, they may still be connected to the UK inheritance tax framework.

For a QNUPS holder, that can change the entire planning analysis.

Two examples: why residence status changes the answer

Consider two expats who both hold QNUPS, but whose UK residence histories create very different planning outcomes.

The first is in their early 60s and spent the first 20 years of their career living overseas on international assignments. During that period, they built up significant international pension benefits. Before returning to the UK, they transferred their international pension benefits into a QNUPS as part of a wider retirement and estate-planning strategy.

They then spent the next 15 years living and working in the UK during the later stages of their career. Over that period, the QNUPS continued to grow in the background. In 2024, they left the UK again and are now preparing for retirement overseas.

At first glance, they may feel that the QNUPS is an old offshore pension and therefore separate from the UK. But their recent 15 years of UK residence may be highly relevant. Under the long-term residence rules, they may still be within the UK inheritance tax framework after leaving the UK. If they die after 6 April 2027 while still within that long-term residence period or post-departure tail, the QNUPS may need to be considered under the new pension inheritance tax rules, depending on the scheme and facts.

The second is in their late 60s and left the UK more than 15 years ago. They spent most of their senior career overseas, built up international retirement assets while non-resident, and established a QNUPS using those non-UK pension benefits and offshore savings. They have remained non-resident for more than 10 consecutive tax years, have no realistic intention of returning to the UK, and are now retiring permanently outside the UK.

Their QNUPS may look similar on paper to the first person’s, but the inheritance tax analysis could be very different. If they are no longer a UK long-term resident, and the QNUPS is established outside the UK, the structure may not be brought into the UK pension inheritance tax framework in the same way. That does not mean it should be ignored. The scheme still needs to be reviewed for costs, investment performance, income options, beneficiary planning, local tax treatment, and its suitability for retirement. But the UK inheritance tax question may be materially different from someone who has only just left the UK after a long period of UK residence.

That contrast is the key point.

The QNUPS label does not decide the outcome. The member’s UK residence history, how long they have been non-resident, where the scheme is established, how it was funded, who the beneficiaries are, and where the member may live in future all need to be reviewed.

Will QNUPS be included in someone’s estate from 2027?

For a UK long-term resident, potentially yes.

From 6 April 2027, qualifying non-UK pension schemes are brought into the pension inheritance tax framework for UK long-term residents, subject to the detailed rules and exemptions. This means a QNUPS should not automatically be assumed to sit outside the UK estate simply because it is established offshore.

For a non-long-term UK resident with a non-UK established QNUPS, the position can be different.

So the correct answer is not “all QNUPS are now inside UK inheritance tax”. The correct answer is that the outcome depends on the member’s residence status, the scheme’s establishment, the scheme status and the detailed rules.

This is why old QNUPS planning needs to be reviewed before the 2027 pension inheritance tax changes take effect. The structure may still work, but the old assumption that “offshore equals outside UK IHT” is no longer safe enough on its own.

The scheme’s establishment country now matters

A QNUPS review should also confirm where the scheme is legally established, because the inheritance tax position can depend on both the member’s residence status and the scheme’s location.

For someone who is a UK long-term resident, or still within the UK inheritance tax tail after leaving the UK, a qualifying non-UK pension scheme may fall within the UK pension inheritance tax framework from 6 April 2027, even if the scheme itself is established overseas. This is the point many older QNUPS holders may not realise, because the fact that a pension is offshore does not automatically mean it sits outside the UK inheritance tax framework for a long-term UK resident.

For someone who is a long-term UK non-resident, the tax treatment may differ. If the QNUPS is genuinely established outside the UK, it may not be brought into the UK pension inheritance tax framework in the same way. That is why the review needs to confirm where the scheme is legally established, whether it is genuinely non-UK established, whether it still meets the QNUPS requirements, whether the scheme's status has changed, and whether the administrator can provide evidence of the position.

For clients who have held the structure for many years, this may not be obvious from the annual statement. The pension may have an offshore label, but the legal and tax position needs to be confirmed before any planning assumptions are made.

QNUPS should not be reviewed like ordinary offshore bonds or trusts

A QNUPS is not an offshore bond. It is not a bank account. It is not simply a discretionary trust. It is a pension arrangement.

That means it should be reviewed through both a pension and a tax lens. The review should consider the purpose of retirement, access rules, benefit options, contribution history, investment suitability, liquidity, scheme administration, and death benefit procedures.

Some QNUPS may involve trustees. That does not make the structure the same as a trust. Some QNUPS may hold investment assets. That does not make it the same as an offshore bond. Some QNUPS may have estate planning consequences. That does not make it purely an inheritance tax shelter.

The danger is that clients sometimes understand the structure only in terms of its tax outcome. A proper review needs to understand how the pension actually works.

What assets are inside the QNUPS?

This is another area that can be missed.

QNUPS can sometimes hold a wider range of assets than a conventional pension, depending on the jurisdiction and scheme rules. That can be useful, but it can also create complexity.

The review should ask what assets are actually held inside the QNUPS.

• Are they liquid enough to support retirement income?

• Are they suitable pension assets?

• Are they valued properly?

• Are there private company shares, property interests, structured products, loans, concentrated positions or illiquid investments?

• Are there connected party arrangements?

• Would the assets be difficult to sell if income or tax payments were needed?

This matters even more after the 2027 pension inheritance tax changes. If the structure needs to be valued for inheritance tax purposes, illiquid or hard to value assets can create practical problems for personal representatives and beneficiaries.

A QNUPS may be technically valid but practically awkward. That is still a planning issue.

A QNUPS is not a tax free asset

A QNUPS can have UK inheritance tax consequences, but the wrapper itself does not magically resolve all tax issues.

The tax treatment of income, growth, withdrawals and death benefits can depend on where the scheme is established, where the member lives, where beneficiaries live, what assets are held, how benefits are paid and what local rules apply. The UK position is only one part of the picture.

This is especially important for expats who may move to another country again. A QNUPS that works efficiently while the member lives in the UAE may not function the same way if they retire in Spain, Portugal, France, Italy, South Africa, Australia, or the UK.

A QNUPS review should therefore consider future residence, not just current residence.

Cross-border planning breaks down when structures are reviewed only against today’s address.

The family administration problem after 2027

Tax is not the only issue. Administration matters too.

From April 2027, when pension values become relevant for inheritance tax, personal representatives may need to identify pension schemes, contact scheme administrators, request pension values, obtain beneficiary information and account for inheritance tax where relevant.

For offshore pension structures, this can become more complicated. Trustees, administrators, beneficiaries and personal representatives may be in different countries. The QNUPS may hold assets that are not easy to value. Beneficiaries may not understand the structure. Documentation may need to be obtained from overseas. Local tax advice may be required in more than one jurisdiction.

A QNUPS may work well while the member is alive, but create friction for the family after death.

That does not mean the structure is unsuitable. It means the beneficiary process needs to be reviewed before the family is forced to deal with it.

What may still work?

A QNUPS may still be useful where the member is not a long-term UK resident, the scheme is established outside the UK, the structure is well administered, the costs are justified, the investment strategy is suitable, and the beneficiary planning is clear.

It may also remain relevant for internationally mobile clients who need a non-UK pension structure, have no realistic intention of returning to the UK, have beneficiaries outside the UK, and want to hold long-term retirement assets in an arrangement that is not tied to a UK-registered pension.

The keyword is “may”. A structure is not suitable because it is offshore. It is suitable only if it continues to improve the client’s position.

What may no longer work?

The original inheritance tax assumption may no longer hold for a long-term UK resident after the 2027 pension inheritance tax changes. The member may still be within the UK long-term residence tail after leaving the UK. The beneficiaries may now live in the UK. The costs may have become harder to justify. The investments may no longer suit the retirement plan.

The structure may also be poorly understood. Some QNUPS hold legacy portfolios that have not been benchmarked properly for years. Others hold illiquid or concentrated assets that could be difficult to value or sell. Some clients no longer have an active adviser reviewing whether the structure still fits.

The word “QNUPS” does not guarantee suitability. It only tells you where the review needs to begin.

Why a QNUPS should not automatically be unwound

A QNUPS should not be kept merely because it is old, nor should it be unwound simply because the rules have changed.

It should be reviewed because the facts matter.

For some clients, keeping the QNUPS may still be the right answer. The member may be outside the UK long-term residence net. The scheme may be non-UK established. The investment strategy may be appropriate. The fees may be reasonable. The beneficiaries may be outside the UK. The structure may still serve a genuine retirement purpose.

Unwinding the QNUPS may also create problems. There may be tax consequences, exit charges, investment disruption, liquidity issues, or loss of features that still matter. Moving assets out of a pension-style structure may also create estate-planning, reporting, or local-tax consequences.

The review should not begin with “Close it”. It should begin with “Does it still work?”

QNUPS vs QROPS: why the distinction matters

QNUPS and QROPS are often confused, but they are not the same thing.

A QROPS is a qualifying recognised overseas pension scheme that may receive transfers from UK-registered pension schemes if the relevant conditions are met. A QNUPS is a qualifying non-UK pension scheme for inheritance tax purposes.

Some overseas schemes may be both. Others may not.

This matters because the rules around transfers, reporting, tax charges, benefit access and inheritance tax can differ. A client who transferred a UK pension overseas may be dealing with a QROPS. A client who funded an offshore pension structure with cash or investments may be dealing with a QNUPS. Some clients may have both.

Before any planning recommendation is made, the adviser needs to know exactly which structure is being reviewed.

Can a QNUPS receive UK pension transfers?

A QNUPS is not automatically a QROPS. Only a qualifying recognised overseas pension scheme can receive UK-registered pension transfers without the transfer being treated as unauthorised, subject to the relevant UK rules and charges. Some overseas schemes may be both QROPS and QNUPS, but this needs to be confirmed before any transfer is considered.

This is another reason not to rely on labels. The structure needs to be confirmed before advice can be given.

What a proper QNUPS review should include

A proper QNUPS review should begin by identifying the exact scheme type, jurisdiction and legal establishment. It should confirm whether the structure is a QNUPS, a QROPS, both, a former QROPS now called a ROPS, or another international pension arrangement.

It should then revisit the rationale for the original advice:

• Was the structure created for retirement provision, inheritance tax planning, investment flexibility, offshore wealth planning, beneficiary planning, or a mixture of these?

• Was the contribution history proportionate and defensible as retirement planning?

• Was the member’s age, wealth and retirement needs properly considered?

The review should then assess current value, asset composition, liquidity, charges, investment performance, drawdown rules, death benefit process, beneficiary nominations, beneficiary residence and scheme administration quality.

The tax review should consider the member’s current and future residence, UK long-term residence status, post-departure IHT tail exposure, the scheme's establishment country, and the 2027 pension inheritance tax rules. It should also consider whether the structure creates local tax issues in the member’s country of residence or the beneficiaries’ countries of residence.

Finally, the review should compare realistic alternatives. The right answer may be to keep the QNUPS. It may be to restructure the investments. It may be to update beneficiaries. It may be to draw benefits. It may be to stop further contributions. It may be to compare the QNUPS with trust planning, offshore bonds, lifetime gifting, or other estate planning options. It may be to take no action, but only after the structure has been properly tested.

The pattern I often see with expats

The pattern I often see is that the QNUPS was created years ago and then left in the background.

The client remembers being told it was outside UK inheritance tax, useful for expats, or a clever offshore pension structure. They may not remember what the purpose of the retirement was, which assets were contributed, which fees apply, how the death benefits work, who the beneficiaries are, or what happens if they become a long-term UK resident under the new rules.

Meanwhile, life moves on. The client’s children may now live in the UK. The client may be considering retiring in Europe or returning to the UK. The original adviser may no longer be involved. The portfolio may not have been reviewed properly. The rules may have changed more than the client realises.

That is the real risk.

Not that the QNUPS exists, but that it is being trusted under assumptions that may no longer apply.

The common mistake

The common mistake is assuming that, because a QNUPS was created for inheritance tax planning, it must still be inheritance tax-efficient.

That is not how cross-border planning works.

A structure is only as strong as the rules, residence position, funding history, retirement purpose, family situation and objectives it is built around. When those change, the structure needs to be retested.

This is especially true for QNUPS because the planning often spans several layers: UK inheritance tax, overseas pension rules, local tax treatment, investment governance, trustees, beneficiaries, and future residence.

The danger is not complexity itself. The danger is the complexity nobody is actively reviewing.

What should you have at the end of a QNUPS review?

At the end of a proper QNUPS review, you should understand whether the structure still works, whether it is affected by long-term residence, whether the 2027 pension inheritance tax changes matter, whether the funding history raises questions, whether fees remain justified, whether performance is acceptable, whether beneficiaries are protected and whether the structure still supports genuine retirement planning.

You should also understand what not to do.

Sometimes the right answer is not to unwind the QNUPS. Sometimes it is to keep the structure but change the investment strategy. Sometimes it is to update beneficiaries. Sometimes it is to stop further contributions. Sometimes it is to draw benefits.

Sometimes it is to compare the QNUPS against alternative estate planning or pension structures.

The value of the review is not movement. It is clarity.

Before you assume your QNUPS still protects your estate, retest the reason it was created

Many expats were advised to use QNUPS years ago for reasons that may have been valid at the time. If that applies to you, the aim is not to criticise the original planning or assume the structure is now wrong. The aim is to make sure it still works under the rules that apply today.

The UK inheritance tax framework has changed. Pension death benefit rules are changing. Your residence position, family circumstances, beneficiaries, retirement plans and investment needs may also have changed since the QNUPS was first created.

Thomas Sleep works with UK-connected expats across the Middle East to review QNUPS and other offshore pension structures in the context of long-term residence, inheritance tax, retirement income, beneficiary planning, investment performance, charges and future retirement location.

The purpose is not to unwind a QNUPS by default. It is to answer a more useful question:

Does your QNUPS still improve your position under today’s rules, or are you relying on an old structure built around assumptions that may no longer apply?

A proper review should tell you whether the QNUPS still works, whether the 2027 pension inheritance tax changes affect it, whether the funding history is defensible, whether the costs remain justified, whether beneficiaries are properly protected, and whether the structure should be kept, restructured, unwound or compared with other planning options.

Book a complimentary QNUPS pension review with Thomas before the 2027 pension inheritance tax changes take effect, and find out whether your offshore pension still does the job it was created to do.

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Final takeaway

A QNUPS may still be useful for some expats. But it should not be left untouched simply because it was once recommended.

The UK’s inheritance tax framework has changed. Pension death benefit rules are changing from 2027. Qualifying non-UK pension schemes are now part of the pension inheritance tax conversation for long-term UK residents. For UK long-term non-residents with non-UK established pension schemes, the position may be different, which is exactly why the residence analysis matters.

The question is not whether QNUPS are good or bad.

The question is whether your QNUPS still does the job it was set up to do, or whether it is now an old structure built for a tax world that no longer exists.

About Thomas Sleep and Skybound Wealth

Living internationally changes everything about how money works.

Income can rise quickly. Tax can fall away. Assets build across countries, currencies, and legal systems. On the surface, life often looks successful. Underneath, complexity accumulates quietly, and small decisions made in isolation begin to shape outcomes years in advance.

Thomas Sleep is a UK-qualified Financial Adviser at Skybound Wealth, specialising in cross-border financial planning for expatriates and internationally mobile families. Based in Dubai, he advises professionals, senior executives, and business owners across the Middle East, the UK, Europe, and offshore jurisdictions.

With over sixteen years of experience living and working abroad, Thomas helps clients bring clarity to complex financial lives. His work spans investment strategy, tax efficiency, retirement planning, and long-term wealth protection, aligning these areas into a single, forward-looking plan that adapts as circumstances and locations change.

Thomas is UK-qualified and regulated and holds the CISI Level 4 Financial Planning &

Advice Diploma. Through Skybound Wealth, he provides regulated advice within a firm known for its strong governance, international regulatory coverage, and client-first approach. His advice is measured, analytical, and outcome-driven, helping clients understand not only what decisions to make today but also how those decisions affect flexibility, tax exposure, and security over the decades that follow.

As both an adviser and an expat himself, Thomas understands where problems typically emerge. Wealth grows faster than planning. Assets are built in silos. Tax considerations evolve quietly until they can no longer be ignored. By the time these issues surface, options are often narrower and more expensive to implement.

Much of Thomas’s work focuses on identifying these risks early and addressing them deliberately. Through Skybound Wealth, he helps clients build resilient portfolios that travel with them, reduce future tax friction, and ensure their wealth supports their family and lifestyle long after their working years end.

This advice is for people who want clarity, control, and confidence that their financial life will continue to work as circumstances change, not just when everything feels stable.

FAQs

What is a QNUPS?

A QNUPS is a qualifying non-UK pension scheme. It is an overseas pension scheme that meets specific UK requirements for inheritance tax purposes. HMRC states that a QNUPS is entitled to the same inheritance tax treatment as a registered pension scheme, but it may not provide similar pension benefits or be structured in the same way.

Is a QNUPS the same as a QROPS?

No. A QROPS is a qualifying recognised overseas pension scheme that may receive transfers from UK-registered pensions. A QNUPS is a qualifying non-UK pension scheme for inheritance tax purposes. Some schemes may be both, but this must be confirmed. The distinction matters because transfer rules, tax treatment, reporting and inheritance tax treatment may differ.

Are QNUPS still outside UK inheritance tax?

Not automatically. From 6 April 2027, qualifying non-UK pension schemes fall within the pension inheritance tax framework for long-term UK residents, subject to the detailed rules. For UK long-term non-residents with non-UK established pension schemes, the position may be different. The answer, therefore, depends on residence status, scheme establishment and the facts.

Should expats with old QNUPS review them now?

Yes, especially where the QNUPS were created years ago and have not been reviewed in recent years. The UK’s move from domicile to long-term residence from April 2025 and the pension inheritance tax changes from April 2027 mean older planning assumptions may no longer hold for every expat. The review should check residence status, scheme status, funding history, charges, investments, beneficiaries and whether the structure still has a genuine retirement purpose.

Can a QNUPS receive a UK pension transfer?

Not necessarily. A QNUPS is not automatically a QROPS. Only a qualifying recognised overseas pension scheme can receive UK-registered pension transfers without the transfer being unauthorised, subject to the relevant UK rules and tax charges.

What are the risks of keeping an old QNUPS?

The main risks include outdated inheritance tax assumptions, long-term residence exposure, layered charges, weak investment governance, unclear beneficiary planning, future changes in residence, funding history concerns, illiquid assets, and unnecessary offshore complexity. The QNUPS may still be suitable, but the reasons for keeping it should be tested.

What should a QNUPS review include?

A QNUPS review should identify the exact scheme type, jurisdiction, establishment country, original advice rationale, contribution history, current residence, future residence plans, UK long term residence status, IHT tail exposure, 2027 pension IHT impact, charges, investment performance, asset liquidity, drawdown rules, beneficiary planning, scheme administration quality and whether the structure should be kept, restructured, unwound or compared with other planning options.