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AdE / INPS
Agenzia delle Entrate / INPS
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Private pensions taxed in residence state (Art. 18 OECD). Public service pensions taxed at source in Italy (Art. 19 OECD) unless recipient is a national and resident of the other state.
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Progressive IRPEF: 23% (up to €28k), 35% (€28k-€50k), 43% (>€50k) + regional/municipal surtaxes.
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7% Flat Tax (Art. 24-ter TUIR) on all foreign income for retirees relocating to Southern Italy municipalities (<20,000 inh.) for up to 10 tax years.
★ Special Expat Flat Tax
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Relief from INPS source withholding via annual double tax treaty certificate (e.g. form EP-I1).
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FA Neubrandenburg / DRV
Finanzamt Neubrandenburg (RiA) / DRV
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Germany applies deferred taxation (Kohortenprinzip): 84% taxable for 2026 retirees. Modern DTTs frequently grant Germany source-withholding rights.
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Progressive Einkommensteuer: 14% to 45% (Solidarity surcharge above threshold). Basic personal allowance: €11,784.
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Application for deemed unlimited tax liability to benefit from the €11,784 Grundfreibetrag if German income is at least 90% of global income.
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Non-resident recipients of German DRV statutory pensions must file returns with Finanzamt Neubrandenburg unless treaty exempt.
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DGFiP / CNAV
Direction Générale des Finances Publiques (DGFiP) / CNAV
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Private pensions taxable exclusively in residence country (Art. 18 OECD). Public service pensions taxable at source in France (Art. 19).
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Progressive income tax: 0%, 11%, 30%, 41%, 45%. 10% standard pension deduction (max ~€4,321). CSG/CRDS applies if resident.
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Non-resident withholding tax (Art. 182 A CGI): 0%, 12%, and 20% tiered brackets on French pensions paid abroad.
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Exemption from French withholding available where treaty assigns exclusive taxing rights to residence country.
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AEAT / INSS
Agencia Estatal de Administración Tributaria (AEAT) / INSS
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Foreign private pensions received by Spanish tax residents are treated as earned income and taxed under IRPF. Modelo 720 asset declaration applies.
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Progressive IRPF (state + regional): 19% to 47%. Base personal allowance of €5,550 (+€1,150 for 65+, +€1,400 for 75+).
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Beckham Law (Special Inpatriates Regime): targeted at employees/digital nomads; standard retirement pensions fall under normal IRPF.
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Foreign tax credit system under DTTs avoids double taxation on pensions taxed at source abroad.
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ESTV / Cantone
Eidgenössische Steuerverwaltung (ESTV) / Cassa Cantonale
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Pillar 1 (AHV) and Pillar 2 pensions paid abroad taxed in residence state under DTTs. Lump-sum withdrawals incur cantonal withholding tax, reclaimable upon proving foreign residence.
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Three-tier taxation: Federal Direct Tax (max 11.5%), Cantonal, and Municipal. Lump-sum capital withdrawals taxed at reduced separate rate.
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Lump-sum expenditure taxation (Pauschalbesteuerung) available in certain cantons for wealthy foreign non-working residents.
★ Special Expat Flat Tax
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Swiss cantonal withholding tax on pension capital refund available by filing cantonal claim with foreign residence tax certificate.
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HMRC / DWP
HM Revenue & Customs (HMRC) / DWP
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UK State Pension is paid gross without tax deducted. Taxed in country of residence under bilateral DTTs. Government service pensions taxed in UK.
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Personal Allowance £12,570 (0%), Basic rate 20% (up to £50,270), Higher rate 40%, Additional rate 45% (>£125,140).
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Abolition of non-dom remittance basis from April 2025, replaced by a 4-year Foreign Income and Gains (FIG) regime for new arrivals.
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Submission of form 'Individual Treaty Relief' to HMRC generates an 'NT' (No Tax) PAYE code to pay private pensions gross abroad.
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AT / Seg. Social
Autoridade Tributária e Aduaneira (AT) / Seguranca Social
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Foreign pensions taxable in Portugal as residence state. Original NHR regime (10% flat tax for 10 years) closed to new applicants since 2024 (grandfathered rights apply).
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Progressive IRS: 13.25% to 48% (+ solidarity surcharge). Specific pension deduction up to €4,104.
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NHR status (10% flat tax on foreign pensions) persists for existing beneficiaries registered prior to 2024. New IFICI scheme targets innovation/research.
★ Special Expat Flat Tax
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Portuguese Tax Residence Certificate (Certidão) eliminates source withholding in the paying jurisdiction.
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BMF / PVA
Bundesministerium für Finanzen (BMF) / PVA
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Private statutory pensions taxed in residence state. Civil service pensions taxed at source in Austria.
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7 progressive brackets: 0% to 55%. 13th and 14th pension payments taxed at preferential 6% fixed rate (Jahressechstel).
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Pensioners' Tax Credit (Pensionistenabsetzbetrag) up to €954 (increased up to €1,488 for low income pensioners).
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Application of exemption with progression or foreign tax credit under BMF double tax treaties.
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Belastingdienst / SVB
Belastingdienst / SVB
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Private pensions generally taxed in residence state, unless Dutch source-state reservation applies on sums exceeding €25,000/year.
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Box 1: reduced first bracket (~19.07% up to ~€38k) for pensioners reaching AOW age (exempt from AOW premium), 49.50% above €75k.
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Elderly Tax Credit (Ouderenkorting) provides substantial tax credits (over €2,000/yr) for low-to-medium income retirees.
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Submission of form 'Vrijstelling loonheffing' exempts AOW state pension from Dutch withholding tax when moving abroad.
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SPF Finances / SFP
SPF Finances / Service fédéral des Pensions (SFP)
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Private pensions taxable in residence state; Belgian civil service pensions taxable at source in Belgium.
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Progressive brackets: 25% to 50% + municipal surcharges (0-9%). Targeted tax reduction on pensions eliminates tax on basic amounts.
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Pension Tax Reduction: non-refundable tax credit up to over €2,500 depending on total retirement earnings.
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Form 276R ensures exemption from Belgian payroll withholding (précompte professionnel) for non-residents under DTTs.
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ACD / CNAP
Administration des Contributions Directes (ACD) / CNAP
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CNAP statutory pensions taxed in residence state under DTTs. EU Institution pensions subject to EU internal tax and exempt from national taxation.
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23 progressive brackets: 0% to 42% (+ 7-9% employment fund surcharge). Favorable tax classes: Class 1a (single 65+) and Class 2 (married).
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Pensioners' Tax Credit (CIP) up to €600/year plus specific pension deduction (abattement) up to €3,000.
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Certificate of foreign tax residence secures an exempt tax withholding card (Fiche de retenue d'impôt).
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Skattestyrelsen / UD
Skattestyrelsen / Udbetaling Danmark
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Denmark actively negotiates DTTs retaining source taxation rights on pension pots accumulated under Danish tax-deferred schemes.
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Bottom-bracket tax (bundskat) + municipal tax (~25%) + top tax (topskat 15% above threshold). Combined marginal cap ~52.07%.
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Personal allowance (Personfradrag) of DKK 51,600 (~€6,900) automatically deducts taxable income for all resident retirees.
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Proof of foreign tax liability required to exempt Folkepension/ATP from Danish source tax under qualifying treaties.
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Skatteverket / PM
Skatteverket / Pensionsmyndigheten
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Swedish pensions paid to individuals living abroad are subject to special non-resident income tax (SINK) at a flat 25% after monthly deduction.
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For residents: municipal tax (~32%) + state tax 20% on higher incomes. For non-residents receiving Swedish pensions: SINK flat tax of 25%.
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SINK tax (flat 25%): simplified withholding without annual tax return filing requirement. Option available to choose ordinary taxation.
★ Special Expat Flat Tax
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Annual application to Skatteverket determines whether 25% SINK or bilateral treaty exemption applies.
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Revenue / DSP
Revenue Commissioners / DSP
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Private pensions taxed in residence state. Irish State Pension paid gross abroad without domestic withholding.
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Standard rate 20% (up to €42,000 for single), Higher rate 40%. Age Exemption for 65+: €18,000 single (€36,000 married).
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Age Exemption & USC Relief: total tax exemption for modest pension incomes and reduced Universal Social Charge (0.5% - 2%) for 66+.
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PAYE Exclusion Order issued by Revenue authorises pension administrators to pay occupational pensions gross abroad.
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KAS / ZUS
Krajowa Administracja Skarbowa (KAS) / ZUS
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Private pensions taxed in residence state. Foreign pensions received in Poland converted and withheld by paying banks.
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12% base rate up to 120,000 PLN (~€28k), 32% on excess. High tax-free amount: 30,000 PLN (~€7,000). 9% health contribution non-deductible.
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Senior Relief (Ulga dla seniora): full income tax exemption up to 85,528 PLN for individuals continuing to work post-retirement age without claiming pension.
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Certificate of Tax Residence (CFR) and form IFT-1R exempt cross-border pension flows between ZUS and partner agencies.
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CfR / Soc. Security
Commissioner for Revenue (CfR) / Social Security
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Malta operates the remittance basis for non-domiciled residents: foreign income taxed only if remitted to Malta; foreign capital gains never taxed.
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Ordinary progressive rates: 0% to 35%. Pension Income Exemption excludes statutory portions up to ~€14,000 from income tax.
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Malta Retirement Programme (MRP): 15% flat tax on foreign pension income remitted to Malta (minimum annual tax: €7,500).
★ Special Expat Flat Tax
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Maltese DTTs allocate exclusive taxing rights to residence state, enabling gross pension payment from foreign sources.
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