What Can You Hold in a SIPP or ISA as an Expat? Funds Explained
UK tax law puts almost no limit on what a pension can invest in. The limits you meet as an expat come from three other places: the property rules that tax certain assets, the list of investments an ISA may hold, and the rules on which funds can be sold to UK retail investors at all. Then your platform adds its own. This post explains each layer, what changes when you leave the UK, why US-domiciled ETFs are not marketed to UK retail investors, and the tax reasons Irish-domiciled UCITS are often considered by expats in Malaysia, Singapore and the UAE.
Key Takeaways
- A SIPP can hold almost any investment under UK tax rules, except residential property and tangible items such as art or classic cars, which trigger tax charges.
- An ISA can hold only qualifying investments, including UK UCITS, recognised UCITS and qualifying investment trusts.
- Inside a SIPP or ISA, a fund without UK reporting status causes no offshore income gain charge.
- An overseas fund can be marketed to UK retail investors only if it is a recognised scheme, and the FCA said in December 2025 that no US fund was one.
What Do the Tax Rules Let a SIPP Hold?
UK tax rules “do not impose any restrictions on the types of asset a pension scheme can invest in”, but residential property and tangible moveable property trigger heavy charges in a SIPP. In practice, that leaves shares, bonds, funds and cash.
HMRC’s Pensions Tax Manual sets the principle. Income from investments held for a registered pension scheme “is exempt from income tax” and gains are “exempt from capital gains tax”. The catch is “taxable property”, which HMRC describes as residential property and items such as “art, antiques, classic cars and also plant and machinery”. Investment-grade gold bullion is an exception.
The charge applies where you can “direct or influence the manner of investments the scheme makes”, which describes most SIPPs. If such a scheme acquires taxable property, HMRC treats it as an unauthorised payment. That brings a 40% unauthorised payments charge on you, a surcharge of 15% above certain limits, and a scheme sanction charge on the scheme, generally 15% of the value on acquisition.
Can You Hold Property Funds?
Usually, yes. Indirect holdings through funds, investment trusts or ETFs can fall outside the charge if the vehicle is genuinely diverse and commercial. HMRC sets conditions for this, including that your scheme and associated persons hold “less than 10%” of most vehicles.
Does Leaving the UK Change What a SIPP Can Hold?
Not under the tax rules. HMRC confirms that membership of a registered pension scheme “is open to anyone regardless of where they are resident”. What changes is your ability to pay in. Relief on personal contributions generally needs UK residence at some time in the previous five tax years and when you joined the scheme. Without UK earnings, relief stops at £3,600 gross a year.
What Can an ISA Hold?
A stocks and shares ISA can hold only investments on HMRC’s qualifying list, which covers shares, bonds, UK UCITS, recognised UCITS, qualifying investment trusts and a few others. The list is narrower than the SIPP rules.
HMRC’s guidance for ISA managers lists the qualifying investments. For funds, the routes that matter are “units or shares in a UK undertakings for collective investments in transferable securities (UCITS)”, “units or shares in a recognised UCITS”, and funds recognised under the Overseas Funds Regime.
Irish and other EEA UCITS reach an ISA in two ways. Those already held in an ISA on 31 December 2020 are grandfathered “for as long as they are held in an ISA.” The UK has also granted equivalence to EEA UCITS (except money-market funds) under the Overseas Funds Regime, so they can apply to the FCA for recognition.
Once you leave the UK, you cannot pay into the ISA, but you can keep it and transfer it to another provider. Whether you can still switch investments within it depends on your provider. Our guide to your UK ISA after moving to Malaysia covers what to do with new savings.
Does UK Reporting Status Matter Inside a SIPP or ISA?
No offshore income gain charge arises on a non-reporting fund held inside a SIPP or ISA. Reporting status matters when you hold an offshore fund outside a wrapper as a UK taxpayer.
Outside a wrapper, the rule is harsh. HMRC says a non-reporting fund is “any offshore fund that does not have reporting fund status”, and a UK investor pays tax on the gain “as if it were income”. HMRC publishes a list of approved reporting funds and updates it monthly.
Inside the wrappers, the charge falls away:
- In a registered pension scheme, HMRC’s Investment Funds Manual says “any gain arising will be exempt from the charge to tax” on a non-reporting fund.
- In an ISA, regulation 22 of the ISA Regulations 1998 exempts the offshore income gain, and HMRC’s helpsheet says you “do not need to declare the income or gains from these funds.”
This matters most if you plan to move back to the UK. Investments held outside a wrapper become subject to the reporting fund rules again once you are a UK taxpayer. Our guide to Irish-domiciled UCITS in a SIPP goes further into fund selection inside the pension.
Why Are US ETFs Not Marketed to UK Retail Investors?
An overseas fund can be marketed to UK retail investors only if it is a “recognised scheme”, and the FCA said in December 2025 that “There are currently no US funds that are recognised schemes in the UK.”
In policy statement PS25/20, answering firms that saw its new disclosure rules as a barrier, the FCA said “Our rules do not create a barrier for retail consumers to access US ETFs.”
The disclosure rules are changing anyway. The Consumer Composite Investments regime replaced the PRIIPs Regulations from 6 April 2026, with a transition period. The FCA says “The full regime and rules in this PS will come into force on 8 June 2027.” It replaces both the PRIIPs and UCITS documents with a single product summary.
| Fund type | Allowed in a SIPP under tax rules? | Qualifying for an ISA? | Sold to UK retail investors? |
|---|---|---|---|
| UK UCITS (OEIC, unit trust) | Yes | Yes | Yes |
| Irish or EEA UCITS | Yes | Yes, if recognised or grandfathered | Yes, if recognised |
| Investment trust | Yes | Yes, if qualifying | Yes |
| US-domiciled ETF | Not barred by tax rules | No, unless recognised | No US fund recognised (FCA, December 2025) |
| Residential property or art | Taxable property charges apply | No | Not applicable |
What Tax Reasons Lead Expats in Asia and the Gulf to Consider Irish UCITS?
Irish funds can benefit from the US-Ireland tax treaty, which caps US withholding on dividends at 15% for a qualifying owner. A Malaysia, Singapore or UAE resident holding US shares directly has no US treaty rate to claim.
Article 10(2) of the US-Ireland treaty limits source tax on dividends to 15% “in all other cases”. The IRS default for US dividends paid to non-residents is 30%, reduced only by a treaty. Malaysia, Singapore and the UAE do not appear in the IRS table of treaty rates. Whether a given Irish fund gets the 15% rate depends on its own eligibility, so check the fund’s documents.
Estate tax is the second reason. The IRS requires a US estate tax return for a non-resident whose US-situated assets exceed $60,000, and US-situated assets include “stock of corporations organized in or under U.S. law”. Irish-domiciled funds are not US corporations. We explain the full comparison in UCITS vs US ETFs for expats in Southeast Asia.
Your platform may still say no. Vanguard, for example, says that after a move abroad its ISA and General Account allow no “deposits, buys or switches”. The tax rules set the outer limit, and your platform’s terms set the real one.
Frequently Asked Questions
Can I keep my SIPP if I move abroad?
Yes. HMRC says membership of a registered pension scheme “is open to anyone regardless of where they are resident”. Your provider’s terms may restrict what you can do after the move. Tax relief on new contributions generally lasts up to five tax years after the year you leave. Our platform guide for non-residents compares five providers.
Can I hold US ETFs in my SIPP?
The tax rules do not bar them, but UK platforms do not market US-domiciled ETFs to retail investors. The FCA said in December 2025 that no US fund was a recognised scheme in the UK.
Can I hold Irish UCITS funds in an ISA?
Yes, if the fund is recognised in the UK or was already in your ISA on 31 December 2020. The UK granted equivalence to EEA UCITS in January 2024, except money-market funds, so Irish funds can apply for recognition. Check the individual fund’s status with your platform.
Does a fund need UK reporting status inside a SIPP?
No offshore income gain charge arises inside the wrapper. HMRC’s Investment Funds Manual confirms the gain is exempt in a registered pension scheme, and regulation 22 of the ISA Regulations exempts it in an ISA. Reporting status matters for funds held outside a wrapper while you are a UK taxpayer.
Can my SIPP own residential property in Malaysia or Thailand?
A SIPP that holds residential property directly faces unauthorised payment charges of up to 40%, plus a 15% surcharge, plus a scheme sanction charge. Diverse commercial property funds and investment trusts are generally outside the charge. See our guide to Malaysia’s property rules for foreigners for buying in your own name.
What changes when the CCI regime starts?
The Consumer Composite Investments regime replaces PRIIPs key information documents and UCITS disclosure documents with one product summary. The legislation started on 6 April 2026, and the full regime comes into force on 8 June 2027. The FCA has said its new rules do not create a barrier to US ETFs. An overseas fund still needs recognition before it can be marketed to UK retail investors.
Related Reading
- UK inheritance tax on pensions from April 2027 for expats abroad
- Drawing your UK pension from Malaysia, Singapore or the UAE
- UK pension options for expats in the Philippines: QROPS and SIPP
- What a portable retirement plan looks like for globally mobile expats
Do you know which domicile each fund in your SIPP has, and what your platform will let you do with it from abroad? If not, that is the place to start. We can talk through what to check and what to ask your platform.
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This content is for informational purposes only and does not constitute personalised financial, investment, or tax advice. By reading this post, you agree to our disclaimer.