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Hoxton Life
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Our podcast takes you inside Hoxton Wealth, where we’re changing the face of international financial planning. From breaking career boundaries to crossing borders, Hoxton Life is your exclusive guide to what it truly takes to succeed at every stage of a financial planning career.
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Hoxton Life
Financial Adviser Explains: What You Need to Know About Transferring Your UK Pension Abroad - with Jess Rooney
Thinking of transferring your UK pension while living overseas?
Before you touch your defined benefit scheme, listen to this.
In this Hoxton Life episode, Jess Rooney (Chartered Financial Planner) breaks down the complexities of transferring a final salary pension - especially for expats.
From currency risk and tax issues, to the emotional shock of investment losses, Jess shares why this isn’t a decision you make lightly.
She also explains why FCA red tape exists - and how the right regulatory advice protects you from irreversible mistakes.
If you’re advising international clients or thinking about your own retirement, this is one to watch.
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Do you think, based on your other circumstances and your assets and your income, your age, your attitude to risk, your capacity for loss, your knowledge and experience of the markets, do you think it's a good idea to essentially look at potentially transferring away?
Speaker 2:We want to help you understand the complexities around moving your defined benefit pension, or final salary pension as they're known in the UK, and I'm very lucky today to have Jess Rooney with us. But Jess is a chartered financial planner and holds all of the qualifications to be able to advise on this specific topic.
Speaker 1:It's not a case of transferring out the scheme and then in two years time, when, say, the investments have not performed as what they wanted to. So I would change my mind. I want to go back.
Speaker 2:It's a decision that you can't reverse and obviously some clients at the end of the day end up unhappy as well because we come back and we will say do not transfer even though they want to transfer and that's where the majority of complaints come from it's my money I want to transfer.
Speaker 1:Why are you not letting me do it?
Speaker 2:so how important is a fixed income for life? Important is a fixed income for life. In this video, we want to help you understand the complexities around moving your defined benefit pension or final salary pension as they're known in the UK and whether this is something you should actually be looking at. A final salary pension has a huge amount of benefits, but it also has potentially a lot of drawbacks for a certain type of person. Ultimately, everyone is different and your situation and what you need to look at depends very much from person to person. It's also mandatory for a UK qualified and regulated financial advisor to look at this for you, no matter where you are in the world. So even if you're in Australia or the US or the Middle East, you still have to have this signed off or the suitability assessed by a UK regulated financial advisor.
Speaker 2:At Hoxton Wealth, we're lucky to have a few of these people working with us, and I'm very lucky today to have Jess Rooney with us, who's had quite the journey as well with Hoxton since she started. But Jess is a chartered financial planner and holds all of the qualifications to be able to advise on this specific topic, so I think we're in for a real treat today topic. So I think we're in for a real treat today. The fine benefit pensions were really topical and have become a bit less topical and we'll get into that as we go forward. But, jess, what are some of the problems that people face when looking at this when they're abroad?
Speaker 1:A lot of people don't really know where to start. It is quite a complex process that people need to go through and, like you said, you do need to have a specific qualification to be able to advise on it. So to find an advisory firm that are willing to give advice, and especially find an advisory firm that are willing to give advice to clients that are not in the UK, is quite difficult to find. So that's the first point of action is to find an advisory firm that can help you. And then a lot of people want to start looking at the defined benefit pension and the options around that, because people don't necessarily need a fixed level of guaranteed income throughout retirement anymore, depending on the circumstances. So it's important to be able to look at alternative options. Most people it might be the case where it is more beneficial for them to stay within the scheme, but for other people and their circumstances it makes sense for them to look at alternative options for it.
Speaker 2:Yeah, it's on like a case by case basis.
Speaker 1:Exactly yeah.
Speaker 2:And every client is different. But when people are living abroad, what are the main reasons that they typically start to look at this? Obviously, you are no longer in the UK anymore. You have got income that is sterling based.
Speaker 1:Yeah.
Speaker 2:It might be a really small part of your overall retirement portfolio. What are some of the reasons?
Speaker 1:That's the main one really is currency risk. You know, if you're living in the US, spending in US dollars and you've got a guaranteed income coming in in GBP, yes, it's guaranteed. However, because of the currency risk of getting it paid into a usd bank account, it's not the actual amount. It's not guaranteed because it can change every month, yearly. However, you get it paid. So that's one main thing. Um, another main thing is once you've moved abroad, obviously you've built up other assets. You may have different income coming in from state pensions, us social security and things like that, which can be quite significant. So having that income paid in on top of the other guaranteed income is generally just taxed at your marginal rate, which then means that you're paying tax potentially unnecessarily, because obviously the other options are keeping it into a pot of money that's invested and you don't necessarily have to draw from it if you don't want to.
Speaker 2:Or you do draw it all quicker, if you wish.
Speaker 1:It becomes more flexible. Yeah, complete flexibility.
Speaker 2:But I suppose obviously you've got this kind of age-old discussion which is flexibility versus fixed income and actually, as we both know, in a lot of circumstances, or in most circumstances in fact, it's actually better for people to retain the fixed level of income rather than give that up. So how important is a fixed income for life?
Speaker 1:It completely depends on your circumstances and the FCA's point of view is that the starting point should always be it's more beneficial and probably more suited for most people to remain in the scheme and only really under unusual or exceptional circumstances is it likely to be a positive recommendation to transfer out of the scheme.
Speaker 1:It's a guaranteed income for life.
Speaker 1:Most of the time it's inflation linked, which means obviously it will keep up or try to keep up with inflation every year, which is very hard to come by these days.
Speaker 1:You can obviously buy an annuity in the UK and I'm sure in other countries as well and where you can get that. But to compare what most people are offered from a defined benefit final salary scheme to what you would buy from an annuity, it actually would cost you quite a lot more to buy it on the open market. So to give up the benefits of a defined benefit scheme is something that people really need to think about and and you know we had these discussions previously where you can't go back on that decision it's not a case of transferring out the scheme and then in two years time when, say, their investments have not performed as what they wanted to. So I would change my mind, I want to go back. It's a decision that you can't reverse, so it's really important that people think about it, have the advice given to them by someone who's qualified to do so, and make sure that they're weighing up the pros and cons yeah, yeah, it's really important, isn't it?
Speaker 2:because it's like you said, it's a one-way door, yeah, like it's not that you can transfer out and then go. Actually, this hasn't worked for me and then I'm going.
Speaker 2:I'm reversing back up now, once you've done it. You've done it, um and yeah, and I think a lot of people underestimate that as well. So it's making sure that you are super, super clear as to the reasons why. One of the other things that you talked about earlier was tax as well, and that's really interesting in a certain jurisdiction, obviously Australia. Do you factor that in when you give the advice as well? So you're not looking at it just from a UK perspective being part of Hoxton because we're international. You're looking at this from a uk perspective being part of hoxton because we're international. You're looking at this from a broader perspective yeah, absolutely, we.
Speaker 1:We take it into consideration. Obviously, I as a uk advisor don't have the knowledge of every single uh, uk sorry tax jurisdiction and how it works in different countries, and we do have a broad knowledge, um, because we've been doing it for a long time of how, say, the tax system works in Australia and the benefits of potentially transferring into a superannuation that has cure-up status in Australia, and so, yeah, we do take it into consideration and we generally have advice from an Australian qualified advisor who would give a more of an understanding of how it would work from a tax point of view, and then we can take that into consideration so it's because I've seen how you've worked before, so you always work with the advisor in the jurisdiction where the client is yeah and ultimately that has to be a regulated advisor.
Speaker 2:So if you're in the us they have to be regulated by the sec. Yeah, here in the uae by esco or the dfsa, um, and obviously if you're in australia has to be by asset. So you work closely with those advisors when you're if you're in Australia it has to be by ASIC, so you work closely with those advisors when you're speaking with clients.
Speaker 1:Yeah, exactly so. We essentially do a two-advisor model. So you have your advisor, who is in the country of your residence, who obviously has a thorough understanding of how that works. Then you have us and me as a pension transfer specialist from the UK side, essentially a TIC-TACS box for you, that's providing you with that UK advice and we're essentially assessing the suitability of whether we think it's appropriate for you to move that defined benefit scheme or not yeah, so it's a nice joined up approach which I think clients like as well, don't they so much?
Speaker 2:which works really well. And you know, one of the key things and I think it's really topical at the moment because I don't, you know, I don't I'm not too sure when this will be released, but as we're recording this, we're going through the tariff tantrums and markets are massively fluctuating. So one of the risks that we talked about and one of the risks I know that you have to heavily consider, is investment risk and people's ability to be able to take that and hold on to that and hold on to that. Can you talk a bit about investment risk? And can you talk a bit about you've moved it now into a SIP or into a Cure-Up and you taking on the investment risk versus you having that fixed income that you don't have to worry about?
Speaker 1:Yeah, well, exactly that I mean. If you're in a defined benefit scheme, then you don't have anything to worry about, there's nothing for you to invest in, it's a guaranteed income and a promise of income for life, and the scheme essentially bears the risk of the investments for you. So that's on them. When you choose to transfer into a defined contribution pension, then the risk is then on you, and we speak to a lot of clients where they go yeah, that's fine, I want to be really high risk and you know I I'm all balanced, or whatever it may be.
Speaker 1:However, when you actually go into how much investment experience they've had before have you invested before? They'll say, no, do you have any experience of volatility in the markets? No, so actually them saying on the basis of it yes, I'm happy to take the risk, but actually have you ever done anything? Have you ever experienced it? How would you actually feel if your investment portfolio dropped by 20%? Are you going to start to panic? Are you going to start to want to disinvest? Um, and obviously it's a long-term approach for most people, um, but there's one thing saying I'm happy with investment risk and there's another thing of actually having to deal with it, especially with your pension funds, which, for most people, is one of their biggest assets yeah, yeah, it's a serious consideration, isn't it?
Speaker 2:and I think that we always say to clients and it'll be useful, it'll be useful now, because I think people forget. It's like how did you feel during this past week?
Speaker 1:yeah, you know like exactly what was you thinking?
Speaker 2:was you thinking, great, this is really, you know, great time to be investing, yeah? Or was you thinking, oh, my god, I'm gonna lose the shirt off my back and waking up with cold sweats, uh, in the middle of night, because, like you said, it all sounds great. But yeah if you, but if it does make you really uncomfortable. The whole point of financial security is to be a bit of a de-stressor, not to add stress onto it.
Speaker 1:De-stressor, and that's definitely one of the pros of a fixed income is you don't have to worry about that, do you? Yeah, it's completely taken off your radar, essentially because it's this nice guaranteed income that is inflation linked for most of the time. It's going up every year. The money comes in and that's fine. And then a lot of people choose to take and keep that guaranteed income and essentially start investing in ices that are in the UK or other investment products outside of the UK, and they use that as a flexible pot instead.
Speaker 2:It's nice to have this nice base, isn't it?
Speaker 1:Nice to have a mix of the two products, having guaranteed income and flexible pot as well, because obviously people do want to be able to access their funds flexibly, whether it be to spend on a renovation on a property or a big holiday in retirement or things like that. But it doesn't necessarily have to come from the defined benefit scheme. Most of the time, other people do have other assets built up, yeah.
Speaker 2:So obviously we've talked about that income now, typically that income is not that that income is for you, but if anything happens to you, typically for your spouse, that's less so maybe you can talk a bit about that and how that impacts things.
Speaker 1:Yeah, so generally speaking there is a spouse's pension. It's rare to see a scheme that doesn't offer a spouse's pension and we generally see that at half. So if you were to pass away and you had a surviving spouse, then half of that generally goes to your spouse. Sometimes we see it at two-thirds in the more generous schemes have you ever seen it?
Speaker 2:100% no, never seen it 100%.
Speaker 1:Yeah, off the top of my head, I don't know any schemes that offer it 100%. It would be nice. It would be nice, yeah, but that's a lot of one of the main complaints for a lot of people when they're wanting to go through this process of looking at alternative options. They feel like they've built up and worked for these companies for so long and then if anything was to happen to them, then their spouse would only get 50% or in a lot of cases you know they're divorced or their partner's already passed, so actually they don't have any WID to pass it on to and they have children that they'd like to pass their assets on to. Most times in schemes when you have children, they are only covered for a children's pension up to a certain age, and it's normally 18 or 21 if still in full-time education. So once they pass that mark, generally speaking, the children's pension doesn't exist anymore. So it's essentially dies with you if you don't have any.
Speaker 2:Survive independence and I suppose, look, if you live till you're 100, that's not really a problem yeah, hopefully. But if you pass when you're 70, or if you do have something like a critical illness, um, you know, or a terminal illness that you know that that is really impacting you, that's something that you, you seriously need to consider. What are the considerations you need to consider around that? Because it's not as simple as saying you know, actually I am terminally ill, I need to transfer that out, because that can be caught in some other uh, legislation, can't it?
Speaker 1:yeah, exactly, and you need to also go to the scheme themselves and tell them I am terminally ill, what you know, what are the options within the scheme? Because sometimes they can offer you alternative options as well. It's not a case of well, you know, the same rule goes for everybody. Sometimes they won't do anything and sometimes they will. But if you transfer out and knowing that you're passing away in a certain amount of years, they can. Essentially there's a rule in inheritance tax that they can get you for as well. So there are quite a lot of considerations to bear in mind when you're looking at transferring out because of ill health or whatever it may be.
Speaker 2:So inheritance tax is a really interesting one, isn't it? Because for so long one of the main reasons or one of the great things about pensions has been that they have not been applicable to inheritance tax. I mean, as it stands today they're still not, but obviously the rules will change in 2027.
Speaker 1:Yeah, how do you see that?
Speaker 2:impacting pensions.
Speaker 1:It's going to have a massive impact on pensions and I'm praying that it doesn't actually come in in 2027 and the rules change again.
Speaker 1:Um, but, like you said, you know it's always been a case of keep money in your pension because it's kept outside of your estate for inheritance tax purposes when it comes to retirement, potentially draw down other assets first and use it last as kind of a legacy planning pot, um, but yeah, I mean, the rules are going to be completely changed and it's quite difficult to plan for something because everyone's now worried about it, but it's difficult to plan for when it's not set in stone, that it is coming in in 2027 yet and it's not been properly passed. So when that day comes, obviously there'll be more planning around that that we can do, um, but for the time being it's um, yeah, it's still kind of up in the air, but yeah, it's going to have a massive impact on things.
Speaker 2:Yeah, it's all very new, isn't it? And I think a lot of people have been looking at different options, obviously now drawing from their pensions and maybe looking to make gifts out of other assets I know that's been talked about. There's also been talks about drawing a regular income out of your pension up to your marginal rate and paying that over, which has been interesting.
Speaker 2:and then for our clients, let's say, that are in australia, or or if they're in um or if they're here, actually transferring the pension into a local scheme takes out of those rules yeah and or also, if you're maybe in the uae, where you have a double taxation agreement, yeah, actually taking the pension out whilst you're here could be a could be a good option yeah as, as well, obviously, making sure that that is completely suitable with your circumstances and all of this good stuff. And that's, I suppose, less for defined benefit pensions, because you would have to transfer it, more for people with with existing schemes exactly.
Speaker 1:Yeah, there is some really clever tax plan that can be done, especially when you're in the areas like the middle east and because of the double taxation agreement and the fact that taxing rights lie with um, the uae, for example and therefore it's zero percent. So there is some really clever tax plan that can be done. Obviously depends on the client circumstances, but yeah, it's a. It's an interesting um and complex, but a great approach to to take yeah, there's so much that you can potentially do isn't there?
Speaker 2:but yet it is so complicated and you know, I think a lot of people get upset at the amount of regulation around this and how difficult it is to transfer out of the scheme. But actually I don't know. I'm sure I know well, I know you feel the same. Um, regulation is really important because, as we said before, this is a one-way door yeah once you go through it, you, you can't, you can't, uh, you can't go back.
Speaker 2:Um, do you see? Do you, do you see a problem? Or do you see it as too high a cost for people to get the regulated advice? They wouldn't do it.
Speaker 1:It is quite costly, but it also, I guess, kind of puts people off wanting to do it.
Speaker 1:And if everybody wanted to look at transferring the defined benefit pension. There'd be a lot of cases where people would transfer it and it's not necessarily suitable for them. So I guess it's good that it's costly and it's complex and it's not an easy process. And when I talk to clients I always say you know it is a kind of a multiple step process. You know you're gonna have to speak to me quite a lot, we're gonna have to go into a lot of detail. So apologies for that and kind of you know, lay it out immediately so that they know what they're going into.
Speaker 1:I do think the the red tape around it is good because I think if it was easy to do, then there would be a lot of people who essentially would regret their decisions in the future because it's very easy to get a cash equivalent transfer value from the scheme and see this big nice number and go oh yeah, I'd like that over £10,000 a year. But actually when you weigh it up and look at potentially how long you're going to live, you have to have a look. Ok, you know that pot of money, I may invest it and it may not do as well as I'd hoped it to, or go on a few big holidays and kind of not manage it properly and draw too much from it and essentially exhaust the pot within my lifetime and I'm left living off state pension money or whatever it may be. So it is important that there's reg tape around it. People are taken through a very, very complex process and given the advice properly.
Speaker 2:Definitely. It's definitely key to work with a good, regulated firm, whether that's Hoxton or someone else. But also I'd echo the thought of what we were talking about earlier, which is super important to make sure that you have two advisors who are regulated and who are singing off the same hymn sheet not singing off the same hymn sheet as in their advice is the same uh.
Speaker 2:And you know ultimately how, when we, when we give any uh financial planning advice on defined benefit transfers, there is a strict chinese wall in between the advisors. That's why you don't have the same person advising on both sides of the fence. But, yeah, it's very, very important to make sure that you do receive proper, regulated advice from a company that has experience in doing this and can demonstrate to you, because, again, you can get all the way through this process and the scheme can turn around and say no.
Speaker 1:Yeah, yeah, exactly. There is very, very strict rules now with transferring even out of defined contribution pensions and defined benefit pensions, and they can red flag it essentially, which means that they're not happy to move the funds across and if you get a red flag, there's not an awful lot you can do about it. So pension schemes are very, very due to now they do their checks and if they see anything that they think you know clients aren't fully aware of what they're doing, they've not been advised properly, or they think you know they've been scammed or by whoever, then they will stop the transfer. So, yeah, it's really important.
Speaker 2:It's really interesting because the actual liability lies on the scheme that's transferring it so if they haven't done their checks, and then they do move it, and it's not what it appeared to be effectively. No wonder, they take it so seriously. When you start this process with someone, walk me through. So you know, I say hi, jess, I'm looking to, I'm looking at whether it would be suitable for me or not to move my defined benefit transfer.
Speaker 1:You know what's the process with you so it depends where you are um, where you are resident. So the process in the uk is very different to the process if you were living abroad, um, but from a uk point of view we would essentially sit down, go through a full, fat, fine process to start off with and then we would look at asking the scheme for a cash equivalent transfer value. So you get one free cash equivalent transfer value every year and you are entitled to request that um up until a year before your normal retirement age. So essentially you are entitled to request that up until a year before your normal retirement age. So essentially you are entitled to transfer out of the scheme until a year before your normal retirement age. Then your statutory right disappears up until that point. But most schemes still do offer you a cash-driven transfer value.
Speaker 1:So you go through a full fact find with your advisor, you request the cash-driven transfer value. Then you sit down and discuss it. Do you think, based on your other circumstances and your assets and your income, your age, your attitude to risk, your capacity for loss, your knowledge and experience of the markets, do you think it's a good idea to essentially look at potentially transferring away? If it's a, if it's a no, then essentially that's where you stop and you can keep reviewing it every year. Like I said, you generally speaking get one cash current transfer value from the scheme for free. So you can keep checking it and see how that's going up or down. But if it is a case where you think yes, ok, based on circumstances, I think it's good advice to potentially look at transferring away. Then you start down the route of going through the advice process.
Speaker 1:So in the UK we do something called abridged advice, which is a high level overview where essentially it doesn't go into an awful lot of detail. But it's essentially two outcomes, unable to determine. Which essentially is us saying we're not 100% sure whether you should proceed or not or whether we think we should transfer out the scheme. So we need to go through things in a little bit more detail and really look at the scheme, how it's set up, you and you, in more detail, or do not transfer, and if you get a, do not transfer. At that stage, essentially you're saying we think it actually is best for you to stay in the scheme. So that's from a uk point of view. From an international point of view, we would essentially look at the cash equivalent transfer value again have the same conversations, and if it was a case of yes, okay, we think it's appropriate then we would go down the route of the full advice document immediately yeah so full advice document, very long 50 page report which um a lot of people get bored of reading through.
Speaker 1:But it is very, very detailed and very, very personalized to you as a client yeah, and it's not generic at all goes through the facts and figures of the scheme, so you're well aware of what you're giving up um and the disadvantages and advantages of potentially moving away yeah, so so, as I've got this right.
Speaker 2:So you go through, you do a fact find, fact find document with the individual is really bring in together all their facts and and circumstances, objectives, family history, all this kind of good stuff to understand where they currently are. And then, once you got back the cetv, you're really saying look, these are the potential benefits, these are potential disadvantages. This isn't advice. You kind of as a client, you decide whether it's something that you do want to consider, yeah, and then you would take them through triage in the UK or abridged advice oh, it's not true, abridged advice in the UK and then you would go to full advice, whereas internationally you would typically just go straight in, straight to full. Yeah, yeah, but we kind of skip over that.
Speaker 2:Um, and that's down to the non-contingent part of it, isn't it? So, yes, and I think this is super important for people to understand once you go down that route, yeah, in the UK the abridged advice is much cheaper because it's not full advice, yeah than if you go down full advice. Now, it's a regulatory requirement in the UK to make sure that, regardless of whether you transfer or not, there is a fixed fee for this advice. So, even if you move or if you don't move. We as advisors are not incentivised one way or the other. That's correct.
Speaker 1:Exactly yeah. So once you've essentially had the abridged advice and it's saying yes, proceed to the full advice. Um, then essentially you're signing to say I'm happy to pay this fee whether the advice is to transfer or to not transfer. Um, because our advice can't be on the back of okay, if you're, we will only charge you if it's a transfer, because obviously then there's conflict of interest in that yeah, yeah, and obviously we don't want there to be any conflicts for anyone Not that there ever would be but you can understand why they've made it non-contingent.
Speaker 2:And obviously some clients at the end of the day end up unhappy as well, because we come back and we will say do not transfer even though they want to transfer.
Speaker 1:And that's where the majority of complaints come from. It's my money I want to transfer. Why are you not letting me do it? But obviously we have to be very uh, stringent and regulated and stick by the fca rules. So I understand the frustration from a lot of clients but unfortunately we have to, you know, stick by the rules and play by the book.
Speaker 2:So yeah, of course, which, which, which we always would do, and we and we always do. Yeah, um, so if someone was to want to kick this off and look at it, what advice would you give them now?
Speaker 1:speak to an advisor.
Speaker 1:Speak to an advisor first, go through the fact-finding process.
Speaker 1:Um, because it is really important to make sure that the advisor knows a lot about you, your circumstances, your family situation, your income, your other assets, your expenditure like that, what your plans for retirement are, what your main reasons for wanting to do it are.
Speaker 1:Because if it's a case of a client comes through and says you know, I want to do it because I need more flexibility, then maybe just the advisor looking at the client's assets and saying, well, why don't you take your flexibility from these assets rather than having to give up this guaranteed income?
Speaker 1:Yeah, um, and that could be oh, I've never actually thought about that perfect. So I definitely guarantee, recommend speaking to an advisor first and having that conversation, and then they will always obviously provide you with some sort of advice to say, okay, actually, yeah, let's have a look at it. It could be the case of the advisor may not necessarily think it's a good idea, but for a client to have the cash equivalent transfer value just to kind of have an idea of what it would be and potentially in the future, get one every year and then see how that progresses, because it may be a case of it's not suitable now, or we don't think it's suitable now, but in five years time, when you're a little bit closer to retirement age, or 10 years time when you're close to retirement age, then maybe we look at it again yeah, cool, awesome.
Speaker 2:Well, I hope you found that really useful. Um, I definitely have learned a lot, uh, from that as well. Defined benefit transfers are not a simple area of advice. They're extremely, extremely complex. Whether you get the advice from us and jess at hoxton wealth, or whether you get it from someone else, always make sure that your advisor is regulated, always make sure that they have the qualifications to be able to advise, and we wish you the best of luck with it. Thanks very much, and I hope you found that video useful.