Taxes on your pensions when you retire abroad

1. Where are you tax resident? Your country of tax residence normally taxes your worldwide income, pensions included. Each country has its own test (section 2).
2. Who has the right to tax each pension? When two countries could tax the same pension, a tax treaty between them decides, and the country of residence usually gives a credit for tax paid in the other (section 3).

• The common rule is 183 days. Most of our destinations make you resident if you spend more than 183 days there in a year (Thailand 180, Malaysia 182). Many add other tests: a home you keep available, your family, or the "centre of your vital or economic interests". Each country page gives the exact rule.
• You can be resident in two countries at once (for example if you keep a home in your old country). Tax treaties then settle it with a series of tie-breakers: permanent home, then centre of vital interests, then habitual abode, then nationality ¹.
• Leaving is a formality too: tell your home tax office you are leaving (UK: form P85 if you do not file Self Assessment) ². Until you can show you have left, your old country may still treat you as resident.

Most treaties follow the OECD model treaty, with variations ¹.

• Private pensions (company pensions, personal pensions, annuities): usually taxed only in your new country of residence (OECD model, Article 18).
• Government service pensions (civil servants, the military, teachers in some countries): usually taxed by the country that pays them (Article 19(2)), unless you are a national of your new country.
• Social security pensions (US Social Security, UK State Pension, CPP/OAS…): each treaty decides, and they differ a lot. US Social Security, for example, is taxable only in the US for residents of France, Malta, Cyprus, Mexico, Thailand, the Philippines and Indonesia, but only in Ireland for Irish residents (see the guide for Americans).
• No treaty? Both countries can tax under their own rules; your home country usually gives a credit for the foreign tax, but not always.

Real treaties have exceptions (lump sums, transfers between pension plans, the US "saving clause"…): read the one between your two countries, or ask an adviser.

Each line is a summary of the country page, where every fact links to its source (PwC tax summaries, national tax authorities, treaties). Rules change with each budget: our tax data is reviewed every three months.

United States

US citizens are taxed by the US wherever they live, on their worldwide income ³. Living abroad also brings reporting duties: the FBAR if your foreign accounts together exceed $10,000 at any time in the year, and Form 8938 if your foreign financial assets exceed $200,000 at year end or $300,000 at any time ($400,000 / $600,000 for a joint return) when you live abroad ³. See also our guide for Americans.

United Kingdom

Once you are non-resident, the UK does not tax your income from outside the UK, but UK income can stay taxable in the UK; double taxation agreements prevent paying twice. Tell HMRC you are leaving (form P85, or your Self Assessment return) ². Which country taxes each UK pension (State Pension, workplace pension, government pension) depends on the treaty with your new country.

Canada

Old Age Security and CPP/QPP pensions paid to a non-resident are subject to a 25% non-resident tax, deducted automatically, unless a treaty with your new country reduces it: many treaties bring it to 15%, some exempt the first slice of Canadian pensions (CAN$10,000–15,000, not always CPP and OAS) if you file form NR5, and residents of the US and the UK pay 0% ⁴. The OAS recovery tax can also apply to high incomes ⁴.

France

A non-resident is taxed in France only on French-source income, pensions included, unless the tax treaty with the new country gives the pension to that country. Where France keeps the right to tax, the pension funds withhold a non-resident tax, and France applies minimum rates of 20% (30% above €29,579 for 2025 income) unless you opt for the average rate on your worldwide income ⁵. Most treaties give private and basic state pensions to your new country and keep civil-service pensions in France; some keep social security pensions in France too (Malta, the Philippines, Indonesia), share them (Italy) or exempt them abroad (Thailand), and there is no treaty with Costa Rica or Uruguay. Each country page shows the rule for French pensions, with the treaty article.

Germany

German pensions paid abroad are handled centrally by the Finanzamt Neubrandenburg. Whether Germany may tax them depends on the treaty with your new country; when it may, non-residents do not get the basic tax-free allowance, so even a small pension can be taxed ⁶.

Pensions are not the only tax that changes when you move:

• Inheritance or gift tax exists in Spain, France, Italy, Greece, Croatia, Ireland, Colombia (as a gain), Ecuador, Thailand (very large inheritances only), Vietnam and the Philippines (estate tax). It does not in Mexico, Malta, Cyprus, Costa Rica, Panama, Uruguay, Malaysia or Indonesia.
• Wealth taxes apply in Spain, France (on high-value property), Italy (on foreign property and financial assets), Colombia (large fortunes) and Uruguay (on assets located in Uruguay).

The details and thresholds are on each country page. A will that works in both countries matters as much as the tax: see the guide on wills and inheritance in two countries.

1. Count the days you will spend in each country the year you move: that decides where you are resident.
2. List each pension and its type (private, government, social security) and look it up in the treaty.
3. Compare our table with your situation, then check the special regimes (Italy, Greece, Malta, Cyprus, Ecuador, Uruguay) before you move: most must be requested when you become resident.
4. Tell your home tax office you are leaving, and keep proof of your new residence (certificate of tax residence).
5. Americans: plan for the FBAR and Form 8938 every year. Canadians: file form NR5 if a treaty exemption applies.
6. Have both tax returns of the first year prepared by an adviser who knows both countries.