If you have worked overseas and then settled in Australia, you probably have retirement savings sitting in another country’s system, and it probably feels like loose ends that ought to be tidied up. Consolidating everything into one Australian account is an appealing idea.
Whether you can do it depends almost entirely on which country the money is in, and the answers are further apart than most people expect. New Zealand has a purpose-built pathway that works well. The United Kingdom has a narrow and specialised route with a severe penalty for getting it wrong. Almost everywhere else has no pathway at all.
This article sets out where each stands. It is general information rather than advice, and cross-border pension transfers are one of the few areas where proceeding without specialist help is genuinely dangerous.
New Zealand: the one that actually works
The Trans-Tasman Retirement Savings Portability Scheme has operated since 1 July 2013 and lets you move a KiwiSaver balance into an Australian super fund when you emigrate permanently. It is the most functional arrangement Australia has with any country.
The conditions are straightforward:
- You must have permanently emigrated to Australia and be able to evidence it
- The transfer must be your whole KiwiSaver balance. Partial transfers are not allowed
- The receiving fund must be an APRA-regulated complying fund. Self-managed funds cannot receive trans-Tasman transfers under any circumstances
- Participation is voluntary for the funds on both sides, so your KiwiSaver provider and your Australian fund each have to accept it. Not all Australian funds do
The transfer itself is not taxed in either country. That is a deliberate feature of the arrangement, designed so that moving between the two systems does not destroy value.
Three things that surprise people
The New Zealand-sourced amount stays labelled. Once inside your Australian fund, the transferred money remains identifiable as a New Zealand-sourced amount and keeps some New Zealand rules attached to it. It cannot be accessed at Australian preservation age. It can only be accessed once you reach New Zealand’s retirement age, currently 65. It also cannot be used under the First Home Super Saver Scheme.
It cannot go to a third country. If you later move somewhere other than New Zealand, that money cannot follow you. It stays in the trans-Tasman system.
It counts towards your non-concessional cap. The transfer is treated as a non-concessional contribution, which for 2026-27 is $130,000, or up to $390,000 under the bring-forward rules depending on your total super balance. A large KiwiSaver balance can bump into that, and since partial transfers are not permitted, you cannot simply move part of it this year and part next year.
One more point worth knowing if you are moving the other way, or considering it: you cannot cash out KiwiSaver simply because you have moved to Australia. Australia is the exception to New Zealand’s permanent emigration withdrawal rules. Your only genuine choice is transfer or leave it invested.
The United Kingdom: possible, but narrow
UK transfers are where the real complexity sits, and where the cost of a mistake is highest.
Why almost no Australian fund can accept one
A UK pension can only be transferred to a scheme on HMRC’s list of recognised overseas pension schemes, commonly called a QROPS. From 6 April 2015, HMRC required such schemes to prohibit access to benefits before age 55, except on grounds of serious ill health. That age rises to 57 from 6 April 2028.
Australian super law permits release before 55 in a small number of situations, including severe financial hardship and compassionate grounds. Because our funds allow it, they fail HMRC’s test. Almost every retail, industry and public sector fund in Australia was removed from the list in 2015 and has not returned.
Two routes remain. The first is a self-managed super fund with a trust deed specifically drafted to prohibit access before the UK minimum pension age, which is then registered with HMRC. The second is a small number of specialist funds set up for this purpose, of which one retail fund currently appears on HMRC’s list. That list is published regularly and status can change, so it should be verified at the time rather than assumed.
The practical consequence of the SMSF route is that it is generally only available to people aged 55 or over, because the deed restricts membership accordingly. Someone who is 40 and wants to consolidate usually cannot.
The penalty for getting it wrong
Transferring a UK pension to a scheme that is not on HMRC’s list is an unauthorised payment. The resulting UK tax charges are commonly cited as reaching 55 per cent of the amount transferred, once the unauthorised payment charge, the surcharge and scheme sanction charges are added together.
This has caught people out, usually those who checked that their fund was on the list some years ago, or who relied on informal advice. Verify the list on the day, not from memory.
The overseas transfer charge
The UK applies a 25 per cent overseas transfer charge to QROPS transfers unless an exclusion applies. The relevant exclusion here is that you are resident in the same country as the receiving scheme, so an Australian resident transferring to an Australian QROPS is generally not charged.
Two qualifications matter. The exclusion can be revisited: if you stop meeting the residency condition within five full UK tax years of the transfer, HMRC can apply the charge retrospectively. A transfer should only proceed if Australia is genuinely home for the medium term. And there is an overseas transfer allowance, currently £1,073,100, above which the 25 per cent charge applies to the excess even when the residency exclusion is otherwise available.
HMRC reporting obligations on the receiving scheme also continue for ten years after the transfer.
What cannot be transferred at all
The UK State Pension. It is not a fund and there is nothing to move. You can claim it while living in Australia and have it paid into an Australian or UK bank account. Be aware that the UK State Pension is not uprated for residents in Australia, so it is generally frozen at the rate applying when you first became entitled or moved. That is a significant long-run issue and it has nothing to do with transfers, but it is the single most common misunderstanding in this area.
Unfunded public sector schemes. NHS, teachers, police and armed forces schemes have been blocked from overseas transfer since 2015.
Annuities already purchased. Once the money has bought an annuity, it is gone from the transferable pool.
Defined benefit pensions need UK-regulated advice
Funded defined benefit schemes can transfer their cash equivalent value, but where safeguarded benefits exceed £30,000 the UK requires advice from an FCA-authorised pension transfer specialist before the transfer can proceed. An Australian financial services licence does not cover this and an Australian adviser cannot provide it.
Beyond the regulatory requirement, there is a substantive point. Giving up a guaranteed, indexed lifetime income in exchange for a lump sum is a decision that deserves genuine scepticism rather than a checklist. The transfer value can look enormous next to a modest annual pension figure, and that comparison is frequently misleading.
The Australian tax side, which applies to any foreign transfer
Whichever country the money comes from, Australia taxes the growth that occurred while you were an Australian tax resident. This is the part people most often miss.
Applicable fund earnings are broadly the growth in the foreign fund between the date you became an Australian tax resident and the date of the transfer. If the transfer is received within six months of you becoming an Australian resident, there is generally no applicable fund earnings to tax. Miss that window and there is.
Where applicable fund earnings do arise, they are assessable to you at your marginal rate. Alternatively you can elect to have the receiving Australian fund include the amount in its assessable income instead, where it is taxed at 15 per cent. For someone on a high marginal rate that election is usually worth making, and it has conditions attached, including that the amount is paid into the super fund rather than taken personally.
The rest counts as a non-concessional contribution. The portion that is not applicable fund earnings covered by an election counts towards your non-concessional cap: $130,000 for 2026-27, or up to $390,000 under the bring-forward rules depending on your total super balance at the previous 30 June. Your balance also has to be under the general transfer balance cap of $2.1 million for you to make non-concessional contributions at all.
For a substantial UK pension, that cap is the binding constraint. Moving a large pot generally means phasing the transfer across several financial years, which is why UK advisers sometimes split benefits across multiple arrangements before starting. It also means the exchange rate on each tranche matters, since the rate at the time the funds are received in Australia is what determines the Australian figures. Our guide to concessional and non-concessional contributions covers how the caps work.
Everywhere else: usually no pathway at all
This is the part most articles skip, and for a lot of readers it is the answer.
United States. A 401(k) or IRA cannot be rolled into a foreign pension plan. There is no mechanism for it. Withdrawing the money to move it triggers US tax, potentially an early withdrawal penalty, and Australian tax consequences on top. The usual approach is to leave it in place and manage the eventual drawdown, with advice on both sides.
Canada. An RRSP cannot be transferred to a foreign plan either. It stays in Canada until it is collapsed or matures.
Singapore. A CPF balance is locked under Singapore’s own rules and cannot be moved to Australia under any arrangement.
Most other national systems are the same. The UK and New Zealand are the exceptions rather than the pattern, because both have specific arrangements with Australia. If your money is somewhere else, the realistic task is not consolidation. It is keeping track of the account, keeping your contact details current with the provider, and planning how it will be drawn down alongside your Australian super.
When leaving it where it is makes sense
Transferring is not automatically the better outcome, and the article would be doing you a disservice if it implied otherwise. Reasons to leave a foreign pension in place include:
- You are not certain Australia is permanent. For UK transfers this is decisive, given the five-year residency condition attached to the overseas transfer charge exclusion
- You are under 55 and the SMSF route is therefore closed to you
- The balance is modest relative to the cost of establishing and running a compliant SMSF
- You hold defined benefits worth keeping, which is more often than people assume
- Your non-concessional cap will not accommodate the transfer without phasing it over years you may not want to spend on it
Currency exposure is the argument usually made the other way, and it is a real consideration if you will spend your retirement in Australian dollars. It is a reason to think about it, not a reason on its own.
Where Professional Advice Adds Value
Executing a UK transfer is specialist work. It needs an SMSF administrator with QROPS experience, and where defined benefits are involved, an FCA-authorised pension transfer specialist in the UK. That is not something a general Australian planning practice does, and you should be cautious of anyone who suggests otherwise.
What a planner should do is the question that comes first, which is whether a transfer belongs in your plan at all. That covers whether the cap position allows it and over how many years, whether the six-month window is still open or the applicable fund earnings election is the better path, how the foreign balance sits alongside your Australian super in a retirement projection, and whether the currency and access trade-offs actually favour moving.
Quite often the answer is that the transfer is not worth doing, and knowing that before you engage a specialist saves a good deal of money. Where the answer is that it is worth doing, the planning question of how much and when still needs answering before anyone touches the paperwork.
At Money Path, our superannuation advice in Adelaide and retirement advice cover that first question: whether a transfer fits your plan, what it does to your contribution caps, and how a foreign pension should be treated in your retirement projections either way. We work alongside the specialists who execute transfers rather than in place of them. If you have retirement savings overseas and want a clear view of your options, get in touch with the team.
Frequently Asked Questions
Can I transfer my UK pension to my Australian industry super fund?
Almost certainly not. Since April 2015, HMRC has required overseas schemes to prohibit access before age 55, and Australian super law permits release earlier in limited circumstances such as severe financial hardship. Nearly every retail, industry and public sector fund was removed from HMRC’s list as a result. The realistic routes are a self-managed fund with a specifically drafted trust deed, or one of the small number of specialist funds currently on the list. Verify the list at the time rather than relying on older information.
What happens if I transfer to a fund that is not a QROPS?
The transfer is treated as an unauthorised payment, and the combined UK tax charges are commonly cited as reaching around 55 per cent of the amount transferred. This is the single most expensive mistake available in this area, and it usually happens because someone relied on outdated information about a fund’s status.
Can I transfer my KiwiSaver to Australian super?
Yes, under the Trans-Tasman Retirement Savings Portability Scheme, provided you have permanently emigrated, you transfer the entire balance, and both your KiwiSaver provider and your Australian fund participate in the scheme. The receiving fund must be APRA-regulated, so a self-managed fund cannot accept the transfer. The transfer is not taxed in either country but counts towards your non-concessional contributions cap.
Can I access transferred KiwiSaver money at Australian preservation age?
No. The New Zealand-sourced amount remains identifiable inside your Australian fund and keeps some New Zealand rules. It can generally only be accessed once you reach New Zealand’s retirement age of 65, rather than at Australian preservation age, and it cannot be used under the First Home Super Saver Scheme or moved to a third country.
Can I transfer my US 401(k) or IRA to Australian super?
No. There is no mechanism for rolling a US retirement account into a foreign pension plan. Withdrawing the funds in order to move them can trigger US tax and potentially an early withdrawal penalty, along with Australian tax consequences. The usual approach is to leave the account in place and plan the drawdown, with advice in both countries. The position is broadly the same for Canadian RRSPs and Singaporean CPF balances.
What are applicable fund earnings?
Broadly, the growth in your foreign fund between the date you became an Australian tax resident and the date of transfer. If the transfer is received within six months of you becoming a resident, there is generally nothing to tax. Otherwise the amount is assessable to you at your marginal rate, or you can elect to have the receiving Australian fund include it in its assessable income and pay 15 per cent instead, subject to conditions.
Can I transfer my UK State Pension to Australia?
No. The State Pension is not a fund and there is nothing to transfer. You can claim it while living in Australia and have it paid to an Australian or UK bank account. Note that the UK State Pension is generally not uprated for residents in Australia, so it does not increase over time in the way it would for a UK resident. That is worth factoring into any long-term retirement projection.
This article contains general information only. It is not financial, tax or legal advice and does not take into account your objectives, financial situation or needs. Cross-border pension transfers involve the law of two jurisdictions and carry significant risk of loss if handled incorrectly. UK transfers of safeguarded benefits above £30,000 require advice from an FCA-authorised pension transfer specialist, which cannot be provided under an Australian financial services licence. HMRC’s list of recognised overseas pension schemes changes and must be verified at the time of any transfer. Figures are for the 2026-27 Australian financial year. You should seek specialist advice in both countries before acting. Money Path Pty Ltd is a Corporate Authorised Representative (No. 001306822) of Australia National Investment Group, AFSL 522028.
