SIPP Overseas Investment Guide: What You Can Hold and What to Avoid

The Finance Act 2004 and subsequent regulations define what a registered pension scheme may hold as "standard" investments (permissible without any special charge) versus "taxable property" (subject to penal charges).

Permitted Standard Investments

• UK-listed equities — shares listed on the London Stock Exchange Main Market and AIM (subject to platform support)
• Overseas listed equities — shares on approved overseas exchanges; most major global markets qualify (see below)
• Collective investment schemes — unit trusts, OEICs, and investment trusts regulated in the UK or EEA
• Exchange-traded funds (ETFs) — including overseas-domiciled ETFs on approved exchanges
• Government bonds (gilts) and corporate bonds
• Cash deposits — including multi-currency deposits on some platforms
• Commercial property — freehold or leasehold commercial property held directly; one of the more distinctive SIPP features
• Life assurance policies meeting specific criteria
• Futures and options on qualifying investments (platform-dependent)

What Is Prohibited: Taxable Property

HMRC designates certain categories as "taxable property". If a SIPP holds these, the scheme administrator is liable to an unauthorised payment charge of 40% of the value of the taxable property, plus potentially a further 15% surcharge if the scheme sanction charge applies. These are penal charges.

Taxable property includes:

• Residential property held directly — this is the most commonly misunderstood prohibition. You cannot hold your home, a buy-to-let, or any direct residential property in a SIPP. (Residential property held indirectly through a listed REIT or authorised fund is permitted — you are investing in the fund, not holding property directly.)
• Tangible moveable property — wine, fine art, classic cars, jewellery, antiques, coins, stamps. These are sometimes marketed as SIPP-eligible "alternative investments"; they are not. HMRC's position is clear.
• Employer-connected assets — investments in the member's own employer or connected companies that exceed certain thresholds.
• Unapproved overseas investments — investments in schemes or funds not meeting HMRC's standard investment criteria.

The key rule of thumb: if the investment is primarily something you could physically use or live in, it is likely taxable property.

ETFs domiciled in the US — the world's largest ETF market — cannot be sold to UK retail investors under MiFID II rules, which require a Key Information Document (KID) that US-domiciled ETFs do not generally produce. UK SIPP investors are therefore broadly limited to:

• UK or EEA-domiciled ETFs (Irish-domiciled ETFs are the most common — iShares, Vanguard, and SPDR all have large Irish fund ranges)
• UK-listed ETFs from overseas providers that have UK-listed versions

Irish-domiciled ETFs listed on major European exchanges are widely available through UK SIPP platforms and provide access to virtually all major global asset classes and geographies. They are subject to UK reporting fund status rules — most major providers have obtained UK reporting status, which matters primarily for direct (non-pension) holdings.

Within the pension wrapper, the reporting fund status of an ETF does not affect the pension's tax position, because income and gains within the pension are not subject to UK tax. It becomes relevant only if the ETF is held outside the pension.

Not all SIPP platforms will serve clients who live outside the UK. Many have terms of business that restrict their services to UK residents, or to clients resident in the UK or EEA. This is a consequence of regulatory complexity — serving overseas clients may require local regulatory permissions in the client's country of residence.

Before relocating abroad, it is essential to:

1. Check your SIPP platform's terms regarding non-resident clients. Contact their client services team and get confirmation in writing.
2. Confirm your adviser's authorisation — if your financial adviser is FCA-authorised, they are primarily authorised to advise UK residents and EEA residents under the FCA's regime. If you move outside the EEA, your adviser may no longer be authorised to advise you.
3. Consider platforms specifically designed for international clients — a number of SIPP providers and wealth management platforms specialise in serving internationally mobile clients and have appropriate regulatory permissions.

Some platforms serve clients in a defined list of countries only; others apply a case-by-case assessment based on the local regulatory environment. Countries with particularly stringent financial services regulations (the United States in particular) may be excluded entirely.

Global Investments advises internationally mobile clients on SIPP management, investment strategy within the pension wrapper, and platform selection for clients living abroad. We can help you identify SIPP platforms that will serve you in your country of residence, assess the withholding tax implications of your overseas holdings, and ensure your SIPP investment strategy is appropriate for your circumstances and time horizon.

Pension investments can fall as well as rise in value. The value of tax relief depends on individual circumstances. Rules on pension scheme investments may change. This guide reflects the position as at 2026. Seek regulated financial advice before making decisions about your pension investments.