In August 2026, Australia recorded 755,530 short-term visitor arrivals and 10,550 permanent arrivals (source: ABS Overseas Arrivals and Departures). Newcomers who start work in Australia will generally find their employer is required to pay into an Australian retirement savings system known as superannuation, or "super". Many newcomers may also already hold retirement savings from overseas, such as a 401(k) from the United States, a workplace pension from the United Kingdom or a KiwiSaver account from New Zealand. This article explores, in general terms, how Australian super compares with these overseas arrangements, whether overseas savings can be moved into Australian super, including a self-managed super fund (SMSF), and what challenges can be involved.
What Is Australian Superannuation?
Superannuation is Australia's compulsory, employer-funded retirement savings system. Employers generally pay the Superannuation Guarantee (SG), 12% of an employee's ordinary time earnings (the rate that has applied since 1 July 2025), into a super fund (source: ato.gov.au). Employees in everyday jobs such as retail, hospitality, teaching and healthcare commonly earn super entitlements. Individuals can also contribute their own money into a fund, subject to annual caps (see our contribution caps guide for further information).
Money in super is locked away, or "preserved", meaning it generally cannot be accessed until a person meets a condition of release (see the ATO's conditions of release for further information).
Super can be held in various types of funds, including industry, retail and public sector funds, and self-managed super funds (SMSFs), where the members are also the trustees and take direct control of how the fund's money is invested. Further general information is available in our article here.
Temporary residents who leave Australia may be able to claim the super they built up while working here as a departing Australia superannuation payment (DASP), subject to eligibility requirements and withholding tax (source: ATO).
How Super Compares With a 401(k), a UK Pension and KiwiSaver
All of these systems encourage long-term saving with tax concessions and restrict early access, but the mechanics differ. The table below is a simplified, general comparison only.
| Feature | Australian super | US 401(k) | UK workplace pension | NZ KiwiSaver |
|---|---|---|---|---|
| How it starts | Compulsory employer contributions (12% SG) | Employee elects to contribute; employer match is optional | Employer-sponsored; often a defined contribution or defined benefit scheme | Voluntary, but eligible employees are generally automatically enrolled; employer contributes at least 3.5% (from 1 April 2026) |
| Ongoing | Grows through employer and personal contributions, plus investment returns | Grows through employee deferrals, any employer match, and investment returns | Grows through member and employer contributions, plus investment returns | Grows through employee and employer contributions, any government contribution, and investment returns |
| Most commonly accessed | Condition of release met (e.g. turning age 65) | Generally from age 59½ without an additional tax | From age 55 now, rising to 57 in 2028 | Generally from age 65, with limited early withdrawals (such as for a first home) |
Sources: ATO; IRS Topic 558; Royal London; Inland Revenue (NZ); Sorted (NZ). Information accessed and verified on 28 October 2026. Rules and figures change; verify current details with the relevant authority.
Why Moving Foreign Retirement Savings Is Not Like Switching Funds
While moving super between two Australian funds is relatively straightforward, transferring in foreign retirement savings can be considerably more complex, as it involves the tax systems of two countries, often with two sets of pension rules applying at once. A step that may not incur tax in one country may trigger tax in the other, and any errors that arise can be hard to reverse. The table below shows, in general terms, how each source can reach the Australian superannuation system.
| Source | General route into Australian super |
|---|---|
| UK pension | Transfer to a recognised overseas pension scheme (ROPS) |
| NZ KiwiSaver | Trans-Tasman portability scheme |
| US 401(k) | No direct rollover options |
Moving a UK Pension Into an SMSF: A General Overview
A UK pension can generally only be moved into an Australian super fund that is a recognised overseas pension scheme (ROPS) in the eyes of the UK's tax authority, HMRC. Many large industry, retail and public sector funds are not ROPS (source: SuperGuide), so whether a particular fund can accept a UK transfer is something to confirm with that fund first.
A self-managed super fund (SMSF) is one avenue, because its trust deed and rules can be set up to meet the ROPS requirements. From there, moving a UK pension into an SMSF involves rules in both countries. In general terms, the ATO looks at how long a person has been an Australian tax resident when the transfer happens, and the UK looks at whether the receiving fund is a ROPS. Some of the key points are:
- Timing: if a UK pension is transferred within six months of becoming an Australian tax resident, none of its growth is taxed as "applicable fund earnings" (AFE). After six months, growth since becoming a resident is AFE, which is taxed at marginal rates unless an election is made for the fund to pay 15% instead. The election generally requires the whole pension to be transferred (source: ato.gov.au).
- Contribution caps: the rest of the transfer counts as a non-concessional contribution and goes towards the cap (see our 2026-27 caps guide). Going over the cap can mean extra tax.
- UK rules: transfers to a scheme that is not recognised as a ROPS can attract UK charges of up to 40% (source: Royal London). A separate 25% overseas transfer charge does not usually apply when the member and the fund are in the same country, but a change within five tax years, such as leaving Australia, can trigger it (source: HMRC).
- UK pension income: ongoing UK pension payments are generally taxable in Australia, and a foreign income tax offset may be available (source: ATO).
- UK inheritance tax: from 6 April 2027, unused UK pension funds are due to be brought within UK inheritance tax, which may be relevant for people who have moved to Australia (see Burges Salmon).
The diagram below shows the general steps in a simplified form.
The information above is a high-level overview only. Moving a UK pension is a complex process, and specialist advice from a suitably qualified professional experienced in both Australian and UK pension rules should be sought before any decisions are made.
Moving a New Zealand KiwiSaver Balance to Australia
KiwiSaver balances can move to Australian super under the Trans-Tasman Retirement Savings Portability scheme. The ATO sets out the following general features (source: ato.gov.au):
- The scheme is voluntary, and only APRA-regulated complying super funds and KiwiSaver providers can take part.
- The member must be moving to Australia permanently or indefinitely, and needs an Australian tax file number.
- The whole balance must be transferred, and the receiving fund must be a complying APRA-regulated fund. Self-managed super funds are not allowed to receive transfers under the scheme.
- The transfer itself is not taxed, but NZ-sourced savings count as non-concessional contributions and are subject to the cap.
For someone who wants their KiwiSaver savings in an SMSF, the ATO's description indicates the portability scheme is not the route.
What About a US 401(k)?
US expatriate tax commentary states there is no legal pathway to roll a 401(k) directly into an Australian super fund (source: Expat US Tax). In practical terms, bringing 401(k) money into super, including an SMSF, would generally mean a withdrawal first, followed by a personal contribution. The IRS generally applies an additional 10% tax to early distributions before age 59½ unless an exception applies (source: IRS), the withdrawal may also be assessable in Australia, and the contribution would count towards the Australian caps. Again, the information above is general in nature only and specialist tax advice should be obtained.
Why Specialist Help Matters
There are numerous considerations outlined above which require expert knowledge and guidance to avoid costly mistakes. While Altitude SMSF Accounting does not hold an AFSL and does not advise on foreign pension transfers, where a client is considering this process, we work with, or engage, specialists who consult directly with the SMSF members before and during the process. We also look after SMSF establishment, annual accounts, tax returns and compliance. Have questions? You can contact us online or give us a call on 1300 133 940.
Further Reading
- ATO: Transfer from a foreign super fund to an Australian super fund - Official guidance on AFE, the six-month rule and elections
- ATO: Trans-Tasman retirement savings transfers - KiwiSaver and Australian super
- HMRC: Overseas transfer charge principles - UK rules for transfers to a QROPS
- Altitude: How to Set Up an SMSF - The step-by-step establishment process
- Altitude: SMSF Contribution Caps for FY2027 - Concessional and non-concessional caps
This article has been prepared for general information purposes only and does not constitute financial, investment, legal or taxation advice. Altitude SMSF Accounting Pty Ltd does not hold an Australian Financial Services Licence (AFSL). Foreign pension and superannuation rules are complex, differ by country and change frequently, and the figures quoted may change. Always seek independent professional advice, including advice from suitably qualified specialists in each relevant country, before transferring any retirement savings.