UK Pension Transfers Abroad: QROPS and the Overseas Transfer Charge
QROPS (Qualifying Recognised Overseas Pension Scheme): the UK regime allowing transfer of UK pension funds (defined contribution, personal pensions, SIPPs, some defined benefit) to qualifying overseas pension plans. QROPS requirements: the overseas scheme must be HMRC-registered as a QROPS; must meet minimum pension age (currently 55, rising to 57 in 2028); must provide pension benefits, not access to capital. Overseas Transfer Charge (OTC): a 25% charge on transfers to QROPS applies unless: (1) the member and the receiving scheme are both in the EEA; OR (2) the member is resident in the country where the QROPS is established; OR (3) the QROPS is set up by an international organisation (UN, NATO, etc.). Practical impact: if a UK pension holder moves to Canada and wants to transfer their SIPP to a Canadian RRSP (not a QROPS anyway): 25% OTC would apply. If they move to Gibraltar (EEA) and use a Gibraltar QROPS: no OTC. After QROPS transfer: UK's 'overseas transfer rules' apply for 10 years — if you move out of the qualifying country within 10 years of transfer, a 25% OTC may be applied retroactively. When QROPS makes sense: moving permanently to a country with a QROPS-approved scheme; consolidating multiple UK pension pots abroad; currency risk management (get pension in local currency). When to leave UK pension in the UK: short-medium term stays abroad; when OTC applies; when UK annuity or drawdown rules are acceptable. Defined benefit (final salary) pensions: HMRC's Strong Actuarial Advice requirement — you need formal advice from a Pension Transfer Specialist before transferring a DB pension with a transfer value above £30,000.
Canadian RRSP: No International Transfer, but Treaty Deferral Abroad
Canadian RRSPs cannot be transferred or rolled into foreign pension plans. They must remain in a Canadian financial institution until maturity (RRSP must collapse by December 31 of the year you turn 71 — typically converted to RRIF). For Canadians emigrating: RRSP portability: none — the RRSP stays in Canada as a Canadian account. Management: manage your RRSP remotely from abroad (online banking via your Canadian institution). Tax treatment as non-resident: Part XIII withholding on RRSP/RRIF withdrawals: 25% (lump sum) or 15% (periodic payments) — reduced under applicable DTA. For a Canadian in the UK: Canada-UK DTA reduces withholding on periodic pension payments to 15%. RRSP holdings: review holdings annually — PFIC issues for US persons; foreign withholding on dividends inside RRSP may be irrecoverable for non-residents. Lock-in rules: some provincial pension plans are 'locked-in' — LIRAs (Locked-In Retirement Accounts) have specific rules on when you can unlock. Non-resident RRSP withdrawal strategy: consider strategic RRSP collapses in low-income years abroad — the Canadian Part XIII withholding may be the only Canadian tax cost, and it may be recoverable via FTC in your new country. Compare your effective tax rate in the destination country vs the 25% Canadian withholding — in some cases (Thailand, UAE), you can withdraw RRSP funds at 25% Canadian withholding and pay 0% in your new country.
US 401(k) and IRA: Must Stay in the US
US retirement plans (401(k), 403(b), IRA, Roth IRA, SEP-IRA) cannot be transferred or rolled into foreign pension plans. There is no US regulatory framework for 'qualified rollovers' to non-US plans. The plans must remain in the US. For Americans emigrating: 401(k): leave in your employer's plan (if vested and separated from service: must be >59½ to avoid 10% early withdrawal penalty OR take required minimum distributions at 73). Roll to an IRA: move to a self-directed IRA where you can manage investments remotely. Withdrawals while abroad: subject to US income tax (ordinary rates) + 10% early withdrawal penalty if under 59½ + state income tax if still a state resident. 20% mandatory withholding on 401(k) distributions. Roth IRA abroad: no annual contributions if you have no US-source earned income (FEIE exclusion reduces or eliminates earned income for Roth IRA contribution purposes — FEIE-excluded income does not count as earned income for Roth contributions). Existing Roth IRA balances: continue to grow tax-free; qualified withdrawals are tax-free even while abroad. FBAR: your US 401(k) and IRA are NOT reportable on FBAR (US domestic accounts). Canada-US DTA treatment of US 401(k) for Canadians: the Canada-US DTA covers 401(k) plans — Canadian residents receiving US 401(k) distributions get DTA-reduced withholding from the US; Canada taxes the income with FTC for US withholding.
Australian Superannuation: Permanent Departure Withdrawal Rules
Australian Superannuation cannot be transferred to foreign pension schemes. Super must either: remain in Australia until you reach your 'preservation age' (between 55-60 depending on birth year, with full unrestricted access from 60 or 65 depending on circumstances); or be withdrawn as a 'Departing Australia Superannuation Payment' (DASP) after you permanently leave Australia. DASP eligibility: you must: (1) have held a temporary visa (not Australian citizen or permanent resident); and (2) have permanently departed Australia; and (3) have a super balance to withdraw. DASP tax rates (2026): Taxed element (concessional contributions and earnings): 35% (increased from 38% effective rate under previous rules). Untaxed element: 45%. Tax-free element (non-concessional after-tax contributions): 0%. Working Holiday Maker (WHM — 417/462 visa) DASP rate: 65% (flat rate, applies to all elements). DASP timing: apply to your super fund after leaving Australia and when your visa has expired or been cancelled. If you obtain permanent residency: DASP is no longer available — must preserve super until preservation age. Australian citizens and PRs living abroad: cannot withdraw super via DASP; super preserves until preservation age (benefit is accessible at preservation age even if living abroad). Note: Australia imposes 15% contributions tax and 15% earnings tax inside super — these have already been paid before DASP is calculated. The 35% DASP rate is on top of this.
Singapore CPF: Permanent Departure Withdrawal for Non-Citizens
Singapore's Central Provident Fund (CPF) accumulates compulsory contributions from employees and employers (37% combined for citizens and PRs under 55). On permanent departure from Singapore: CPF withdrawal eligibility: Singapore citizens and PRs can only withdraw CPF in full upon turning 55 (with some conditions) or upon renouncing Singapore citizenship/PR status. Non-citizen employees: CPF is mandatory for Singapore citizens and PRs only — non-citizens on Employment Pass, S Pass, etc. do not contribute to CPF. If you are on a work pass that does not require CPF: no CPF to worry about on departure. If you obtained Singapore PR and then leave: on giving up PR status, you can withdraw all CPF funds subject to standard rules. CPF Retirement Account: at 55, a Retirement Account is set up. To withdraw, you must set aside the Enhanced Retirement Sum (~SGD 426,000 in 2026) — the excess can be withdrawn. CPF LIFE: annuity programme starting monthly payments from 65. On departure as a former PR: you receive a lump sum equivalent to the CPF LIFE premium rather than monthly payments. Tax treatment: CPF withdrawals are not taxable income in Singapore. In your new country: depends on the local tax rules for foreign pension receipts. Under many DTAs, pension income is taxable only in the country of residence — CPF withdrawals received in your new country of residence may be taxable there.