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.

FeatureAustralian superUS 401(k)UK workplace pensionNZ KiwiSaver
How it startsCompulsory employer contributions (12% SG)Employee elects to contribute; employer match is optionalEmployer-sponsored; often a defined contribution or defined benefit schemeVoluntary, but eligible employees are generally automatically enrolled; employer contributes at least 3.5% (from 1 April 2026)
OngoingGrows through employer and personal contributions, plus investment returnsGrows through employee deferrals, any employer match, and investment returnsGrows through member and employer contributions, plus investment returnsGrows through employee and employer contributions, any government contribution, and investment returns
Most commonly accessedCondition of release met (e.g. turning age 65)Generally from age 59½ without an additional taxFrom age 55 now, rising to 57 in 2028Generally 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.

SourceGeneral route into Australian super
UK pensionTransfer to a recognised overseas pension scheme (ROPS)
NZ KiwiSaverTrans-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:

The diagram below shows the general steps in a simplified form.

General pathway for moving a UK pension into an SMSF Five steps: check the UK scheme and age test, make the SMSF a recognised overseas pension scheme, check UK charges, work out the Australian tax and contribution cap position, then meet reporting obligations in both countries. 1 UK scheme and member Type of benefit, member age (55, rising to 57 from April 2028), residency 2 Receiving fund is a ROPS SMSF deed has the required provisions; HMRC notified 3 UK charges and tax Overseas transfer charge, transfer allowance, five-year period 4 Australian tax and caps AFE calculation, 15% election, non-concessional cap, TFN and timing 5 Ongoing reporting SMSF annual return disclosure; ongoing HMRC notification and reporting
A simplified, general pathway only. Each step involves detailed rules in both countries. Original diagram prepared by Altitude SMSF Accounting.

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):

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


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.