QROPS Comparison: Malta vs New Zealand vs Gibraltar

Qualifying Recognised Overseas Pension Schemes (QROPS) allow UK pension holders to transfer their accumulated savings into a pension scheme based in another jurisdiction. The option is most relevant for UK nationals living permanently abroad, non-UK nationals returning home with UK pension rights, and internationally mobile professionals who want to consolidate pensions in a jurisdiction aligned with their place of residence.

The QROPS market has contracted substantially since the introduction of the 25% Overseas Transfer Charge (OTC) in March 2017, and the list of eligible schemes has narrowed. Three jurisdictions dominate contemporary QROPS planning for high-net-worth individuals: Malta, New Zealand, and Gibraltar. Each has distinct characteristics that make it suited to different circumstances.

This guide compares all three. Nothing here constitutes personal financial advice. QROPS rules, tax treaties, and the HMRC approved list change regularly. Always take current, qualified advice before initiating a QROPS transfer.

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The Overseas Transfer Charge (OTC) — The Starting Point

Before comparing jurisdictions, understand the OTC. Since 9 March 2017, a transfer to a QROPS triggers a 25% charge on the transferred value unless one of the following exemptions applies:

1. The member is tax resident in the same country as the receiving QROPS.
2. The QROPS is an occupational pension scheme of the member's employer.
3. The QROPS is an overseas public service scheme.
4. The QROPS is a pension scheme established by an international organisation.

For most private individuals, exemption 1 — the same-country-residence test — is the only realistic route to a charge-free transfer.

Critical change — the EEA exemption is gone: There used to be a further exemption where both the member and the QROPS were in the EEA (so a UK expat resident anywhere in the EU could transfer to a Malta QROPS tax-free, because Malta is in the EEA). HMRC abolished that EEA exemption — and the equivalent Gibraltar exemption — from 30 October 2024. Since then, even an EEA-resident expat transferring to a Malta QROPS faces the 25% charge unless they are tax resident in Malta itself. Transfers requested before 30 October 2024 and completed before 30 April 2025 were protected under transitional rules. (Separately, post-Brexit the UK is itself no longer an EEA country.)

The five-year "clawback" rule means that even if the OTC was not charged at transfer, HMRC can assess it within five full tax years if the member later ceases to satisfy the exemption.

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Malta QROPS

Structure and Appeal

Malta became the dominant QROPS jurisdiction for European expats. Malta is an EU/EEA member state, and its pensions legislation permits QROPS structures that comply with HMRC's rules while offering meaningful flexibility. Note, however, that Malta's EEA status no longer delivers an OTC exemption to expats resident elsewhere in the EU: HMRC abolished the EEA exemption on 30 October 2024, so the same-country-residence test (being tax resident in Malta) is now what matters.

The UK-Malta Double Taxation Agreement (DTA) is central to Malta's appeal. Under the UK-Malta DTA, UK pension income received by Malta-resident individuals is taxable only in Malta — the UK relinquishes its primary taxing rights once the individual is Malta tax-resident and the pension is in a Malta QROPS. Malta's pension tax rates (typically 15–25% on qualifying pension income for non-domiciled individuals under the Global Residence Programme or similar) are generally lower than UK marginal income tax rates for higher earners.

Income Drawdown

Malta QROPS providers (regulated by the Malta Financial Services Authority, MFSA) typically allow flexible drawdown from the QROPS fund. There is no compulsion to purchase an annuity. Members can draw variable income, consistent with the HMRC requirement that the QROPS provides "pension income" rather than acting as a pure tax wrapper.

The HMRC rules require that member functions of a QROPS broadly mirror those of a UK registered pension scheme — which means minimum pension ages, benefit rules broadly consistent with UK norms, and no "pension liberation" arrangements.

Investment Options

Malta QROPS structures typically permit a broad investment universe — equities, bonds, funds, ETFs, cash, and (with appropriate structure) alternative assets. This is often broader than what is available within an employer DB scheme but broadly comparable with a well-established SIPP.

Whom Malta QROPS Suits

Malta is best suited to:

• Individuals who are tax resident in Malta itself (securing the same-country OTC exemption).
• Those who prioritise the UK-Malta DTA protection and want to draw flexible income within an EU-regulated structure.

Since the EEA exemption was abolished on 30 October 2024, an expat living elsewhere in the EU (France, Germany, Italy, Spain, Portugal and so on) no longer transfers to a Malta QROPS free of the OTC — they would need to be tax resident in Malta to avoid the 25% charge.

Malta QROPS are generally not appropriate for:

• UK residents (OTC applies).
• Anyone not tax resident in Malta (the 25% OTC applies, the EEA exemption having been abolished).
• Those who plan to move frequently between jurisdictions (five-year clawback risk).

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New Zealand QROPS

Structure and Appeal

New Zealand QROPS operate under New Zealand's regulated superannuation scheme framework, supervised by the Financial Markets Authority (FMA) of New Zealand. Several New Zealand-based providers have maintained QROPS status over the years, and NZ schemes have historically been popular with members who are not EEA-resident and want to avoid the OTC.

The critical advantage of New Zealand QROPS for non-EEA members: under the OTC rules, the same-country exemption means that a member resident in New Zealand can transfer to a New Zealand QROPS without triggering the 25% charge.

The "No EEA" Position

New Zealand is not in the EEA. Therefore, a non-NZ-resident who transfers to a New Zealand QROPS will trigger the OTC (unless they are themselves resident in New Zealand). For non-NZ residents, New Zealand QROPS have limited appeal in the current regulatory environment.

However, some New Zealand schemes are structured to accept non-resident members where the member intends to move to New Zealand, or where the specific scheme rules and member residence status align. Advice on the specific facts is critical.

Income Treatment

New Zealand does not have a DTA with the UK that is as advantageous as the UK-Malta DTA for pension purposes. UK source pensions transferred to a NZ QROPS may still be subject to UK reporting requirements during the five-year post-transfer period, and the tax treatment of pension withdrawals by NZ-resident members is determined by NZ domestic law.

Under NZ tax law, pension income is generally taxable in New Zealand. However, for members who are resident in New Zealand long-term, NZ tax rates may be competitive compared to UK rates, particularly for higher earners.

Whom New Zealand QROPS Suits

NZ QROPS are most relevant for:

• UK nationals who have emigrated to New Zealand and are permanently resident there.
• Non-UK nationals with UK pension rights who are New Zealand tax-resident.

New Zealand QROPS are generally not appropriate for members resident outside New Zealand or the EEA, as the OTC will apply without a same-country exemption.

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Gibraltar QROPS

Structure and Appeal

Gibraltar is a British Overseas Territory, not part of the EU or the EEA. Gibraltar has its own pensions legislation and a small but established QROPS industry regulated by the Gibraltar Financial Services Commission (GFSC).

The key question post-Brexit for Gibraltar QROPS is the OTC. Gibraltar is not in the EEA. A transfer to a Gibraltar QROPS by a non-Gibraltar resident would normally trigger the OTC unless the same-country exemption applies (i.e. the member is resident in Gibraltar).

Gibraltar has a small resident population (approximately 34,000 as at 2026), but it attracts a disproportionate number of financially mobile individuals — many of whom are UK nationals attracted by Gibraltar's low income tax rates (a flat rate of 10–28% on the first c.£105,000 of income, with a generous allowance structure).

Gibraltar Tax Environment

Gibraltar's Category 2 residence permit (for HNW individuals with a self-contained property in Gibraltar) permits a flat annual tax, and ordinary resident individuals benefit from low income tax rates on pension income. The Gibraltar-UK DTA ensures that UK pension income paid through a Gibraltar QROPS to a Gibraltar resident is not subject to UK income tax.

Regulatory and Practical Considerations

Gibraltar providers are typically smaller than those in Malta. Regulatory oversight is robust but the market is less developed than Malta's QROPS industry. Due diligence on provider quality and financial strength is important.

Whom Gibraltar QROPS Suits

Gibraltar QROPS are primarily relevant for:

• Individuals resident in Gibraltar.
• UK nationals considering relocating to Gibraltar for tax purposes who also want to consolidate pension savings offshore.

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Comparing the Three Jurisdictions

Feature	Malta	New Zealand	Gibraltar
EEA member	Yes	No	No
OTC exemption basis	Same country (Malta-resident) — EEA exemption abolished 30 Oct 2024	Same country (NZ-resident)	Same country (Gibraltar-resident)
UK DTA benefit	Yes (UK-Malta DTA, favourable)	Limited	Yes (UK-Gibraltar DTA)
Drawdown flexibility	Yes	Yes	Yes
Regulatory strength	High (MFSA/ESMA)	High (FMA)	Good (GFSC)
Provider market depth	Good	Limited	Small
Best suited for	EEA-resident expats	NZ-resident expats	Gibraltar residents

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Compliance and Ongoing Requirements

All QROPS holders remain subject to:

• HMRC's 10-year reporting requirement — for transfers made on or after 6 April 2017, the QROPS provider must report payments to HMRC for ten tax years after the transfer (the old five-year window applied only to pre-9 March 2017 transfers).
• Unauthorised payment charges if the QROPS makes payments that would not be permitted under UK registered pension scheme rules.
• OTC clawback if the member moves out of the exemption zone within the five-year period.

HMRC publishes an updated QROPS list (the "ROPS list") quarterly. A scheme appearing on the list is not a guarantee of compliance — it is the member's responsibility to ensure the transfer remains appropriate. HMRC has removed schemes from the list retrospectively, which can create complications for existing holders.

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Provider Selection

Choosing a QROPS provider requires due diligence on:

• Regulatory standing — is the provider regulated by the relevant authority in good standing?
• Financial strength — is the provider adequately capitalised?
• Fee structure — QROPS fees can include establishment charges, annual management charges, and adviser fees. Total cost of ownership matters over a long retirement.
• Investment platform — does the platform offer the asset classes you need?
• Reporting compliance — does the provider have a robust track record of HMRC reporting?

Beware: a number of QROPS providers and intermediaries have been subject to regulatory action for poor conduct or non-compliance. Stick to FCA-regulated UK advisers and well-established overseas providers with clean regulatory records.

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How Global Investments Can Help

Global Investments advises internationally mobile HNW clients on QROPS planning across Malta, Gibraltar, New Zealand, and other approved jurisdictions. We work with clients in the EU, the Middle East, Asia-Pacific, and beyond to identify the optimal pension structure given their current residence, anticipated future moves, and tax position.

We provide independent, whole-of-market advice on QROPS eligibility, jurisdiction selection, provider due diligence, and the critical OTC analysis. Our compliance-first approach means we will tell you clearly when a QROPS is not in your interests, and what alternatives — such as a SIPP combined with a tax-efficient investment wrapper — may serve you better.

This article is for general information only and does not constitute regulated financial advice. QROPS rules, the HMRC ROPS list, and double taxation agreements are subject to change. Tax treatment depends on individual residence and domicile status. The 25% Overseas Transfer Charge can represent a significant cost. Always seek qualified, regulated advice from an FCA-authorised firm before initiating any QROPS transfer.