Retirement Planning Abroad in 2026: QROPS, IRA and Taxes

Retirement planning abroad makes sense for people who already have assets, income or pension rights in another country. It is not a way to pay less tax, because anyone living in Brazil declares here what they receive from abroad. The most expensive mistake is moving a UK pension to a QROPS outside the country where you live: it costs 25%.

This guide covers the three most common situations among Brazilians: a UK pension, a US retirement account and a long-term portfolio built abroad. For each one, it explains the tax rule on both sides.

How does retirement planning abroad work?

It means organizing, in a single plan, three sources that usually stay separate: public social security (INSS and foreign systems), pension plans from employers or governments you worked for abroad, and your own investment portfolio abroad. The goal is to know how much each source will pay, in which currency and with which tax, in both countries.

The question about INSS for people leaving Brazil has its own guide: INSS for people leaving Brazil.

Do social security agreements help?

They help you avoid losing contribution time. Brazil has international social security agreements in force with countries such as the United States, Portugal, Japan, Germany, Italy, Spain and Canada, in addition to the Mercosur agreement and the Ibero-American convention (Ministry of Social Security). With an agreement, time worked in one country can be counted in the other to secure the right to the benefit. Each country keeps paying its own part, under its own rules.

The United Kingdom is not on the list of agreements in force. Anyone who worked there does not add that time to INSS time by agreement; the British pension is treated separately.

Is transferring a UK pension to a QROPS still worth it?

For someone living in Brazil, almost never. Transferring a UK pension to a QROPS (Qualifying Recognised Overseas Pension Scheme) pays the Overseas Transfer Charge, 25% of the amount transferred, except when the holder lives in the same country where the QROPS is established (HMRC, PTM102400). A Brazilian resident who transfers to a QROPS in Malta does not meet that condition.

Until October 30, 2024, there was a second exception, for people living in the United Kingdom or the European Economic Area (EEA) who transferred to a QROPS also in the EEA. The Autumn Budget 2024 repealed that exception (section 244C of the Finance Act 2004). It applied only to transfers requested before that date and completed by April 30, 2025. Since Brazil has never been in the EEA, that exception did not serve a Brazilian resident.

There is also a rule for a later move. If the transfer escaped the tax because the holder lived in the QROPS country and, within the period set by British law, moves away, the 25% tax can be charged afterward.

The text that was on this page until October 2026 recommended a transfer to Malta for a doctor living in São Paulo. Under the rules above, that operation would have cost 25% of the fund to the United Kingdom.

What about a US retirement account (IRA or 401(k))?

For a non-resident of the United States, a withdrawal from a US retirement account is subject to 30% withholding on the gross amount of US-source income, unless a treaty provides an exemption (IRS, Publication 515). Brazil has no treaty to avoid double taxation with the United States, according to the official list of the Federal Revenue Service. That is why a Brazilian who returns to Brazil and withdraws from the account faces the full withholding.

In Brazil, the amount received is also taxable. Tax paid in the United States can only be deducted if there is a treaty or reciprocal treatment between the countries (Law No. 14,754/2023 (Lei 14.754/2023), art. 4). Without a treaty, the deduction depends on reciprocity, which must be checked case by case. Before withdrawing or transferring, run the tax numbers on both sides.

A US person (US citizen or green card holder) remains taxed by the United States on worldwide income, even while living in Brazil. In that case, the IRA and Roth IRA rules continue to apply, and the planning must be done with a US accountant.

How does Brazil tax retirement income and investments abroad?

It depends on the type of income:

Law 14,754/2023 expressly includes "retirement or pension funds" among financial investments abroad (art. 3, § 1, I). Exchange rate variation also counts as income. Anyone with USD 1 million or more in assets abroad on December 31 also files the CBE (Brazilian Capital Abroad report) with the Central Bank. The step-by-step is in how to declare an offshore company on your income tax return.

How do you build a retirement portfolio abroad?

The simplest path is an investment account in your own name, at an international broker, with liquid and diversified assets. For a passive portfolio, it usually costs less than an offshore company, and Brazilian tax only applies when the income is realized. A company abroad that only invests has its profit taxed every year.

• •Currency. Define how much of your future income you will spend in reais and how much in hard currency. The portfolio should follow that spending, not the exchange rate of the moment. See multi-currency strategy.
• •Custody. Prefer regulated institutions in stable jurisdictions. The choice is part of the offshore banking service.
• •Life insurance with investment. Policies such as PPLI can make sense for large estates with a succession goal. The tax treatment in Brazil needs careful analysis. See PPLI for Brazilians.
• •Structure. A company or trust is only justified by succession or governance, never to defer tax. See from what level of wealth an offshore company is worth it.

What if I retire outside Brazil?

Then the question stops being only about investments and becomes one of tax residency. A person who ceases to be a Brazilian resident, with the permanent departure reported to the Receita, stops being taxed here on income from abroad. They begin to follow the rules of the new country of residence. The order of the steps and the care needed with the tax exit are in international tax residency.

In the QROPS case, moving also matters: someone who starts living in the country where the QROPS is located can transfer the UK pension without the 25% tax, as long as they stay there for the period required by the United Kingdom.

Conclusion

Retirement with assets abroad is rules planning, not product planning. The most expensive mistakes come from operations sold as advantageous without running the numbers on both sides: the QROPS for someone living in Brazil, which costs 25% to the United Kingdom, and the IRA withdrawal without a treaty, with 30% withholding in the United States. Before transferring or withdrawing from any plan, calculate the tax in the country of origin and in Brazil and check whether a social security agreement exists. To review your case, book a consultation or see the succession planning service.