Moving Abroad: What Happens to the Altersvorsorgedepot?

Tilman Freyenhagen

Published on 19 August 2026 · Managing Director & Partner, Alsterspree Verlag GmbH

This article was written by an author with the support of AI.

Quick Answer: Your Altersvorsorgedepot When Relocating

If you move abroad, your Altersvorsorgedepot remains entirely your property as a securities depot. Whether you are permitted to retain the accumulated state subsidies or must repay them depends decisively on your destination country: Changing your residence within the European Union (EU) or the European Economic Area (EEA) is non-detrimental for subsidies, whereas relocating to a third country outside the EEA risks a repayment demand for allowances and tax deductions.

This legal framework is grounded in the Retirement Provision Reform Act (AVRG, BGBl. 2026 I No. 156), which received Bundesrat approval on May 8, 2026, with qualifying products available starting January 1, 2027. The core rule differentiates strictly between the European single market and third countries:

• Relocation to an EU/EEA state: All state basic and child allowances received up to the move, as well as special expense tax deductions, remain fully intact. The portfolio continues operating normally while you reside abroad.
• Relocation to a third country (e.g., USA, Switzerland, United Kingdom): Under established Riester principles, establishing residency outside the EU/EEA constitutes detrimental use (förderschädliche Verwendung), meaning the state can demand repayment of all past subsidies granted.^[1]
• Retention of depot assets: Your own contributed capital and accumulated investment gains always remain entirely your property. Any statutory recovery applies exclusively to the state subsidy component.

The Riester Foundation: What Remains of Section 95 EStG

To properly assess the legal framework of the retirement depot (Altersvorsorgedepot), it is worth looking at the historical precedent of the Riester pension. Numerous search results still reference the provisions of Section 95 of the German Income Tax Act (EStG), which defined harmful use when relocating abroad. Originally, the tax authorities reclaimed all state subsidies upon any relocation abroad until the European Court of Justice (ECJ) overturned this practice within the EU/EEA.

With the reform, the Riester pension will be replaced by new, more flexible, and more cost-effective products starting January 1, 2027; a central component is opening state tax incentives to a retirement depot without guarantees.^[2] The extent to which the European-law-driven relocation rules of the Riester framework apply to the new depot can therefore only be described comparatively, rather than as an identical set of rules:

For certified Riester contracts, up to 30 percent of the available capital may be paid out outside the monthly benefits at the start of the payout phase.^[3] Important for savers: Any transfer of old Riester rules to the new depot represents a legal analogy. For the retirement depot, the newly drafted statutory text in the AVRG applies primarily.

Who Is Affected? The Scope Test for Your Relocation

The concrete effects on your savings contract depend on your individual life stage and the status of your contributions. The enacted law (BR-Drs. 206/26) distinguishes between the accumulation phase and the payout phase.

1. Moving during the accumulation phase: If you move before the start of the payout phase and are no longer subject to mandatory German pension insurance or domestic tax liability, your entitlement to new annual subsidies ends. The existing balance continues to earn interest and grow in a tax-optimized manner.
2. Premium waiver vs. continued contributions: You can put the depot on hold while abroad or continue contributing without subsidies. For contributions made without domestic subsidy eligibility, no new government grants will be paid starting from the year of relocation.
3. Returning to Germany: If you return to Germany at a later point and once again become subject to unlimited tax liability or mandatory statutory pension insurance, subsidy eligibility for future savings installments resumes immediately.
4. Moving during the payout phase: With a residence in the EU/EEA, monthly disbursements or the payout plan continue to be paid out without loss of subsidies. If you retire in a third country, the clawback mechanisms of the payout phase take effect.

Note: Calculations and status assessments are model illustrations. Not investment advice within the meaning of § 1 Abs. 1a Nr. 1a KWG.

Retiring Abroad: Payouts and Taxes

Many savers plan to spend all or part of their retirement abroad and have benefits from the retirement depot transferred to a foreign bank account. Whether and to what extent payouts to a foreign account are possible depends on the respective provider contract. Tax-wise, the principle of deferred taxation remains: following the reform, distributions from retirement savings contracts in the payout phase continue to be taxed at the individual income tax rate pursuant to § 22 Nr. 5 EStG.^[4]

The taxation of payouts is governed exclusively by the bilateral Double Taxation Agreement (DTA) between the Federal Republic of Germany and your respective country of residence:

• Allocation of taxing rights: The respective DTA determines whether the right to tax private pension benefits belongs to the country of residence or the source country (Germany).
• No flat country-wide rules: Because each Double Taxation Agreement contains specific clauses for pension benefits, no universally applicable tax rate can be predicted across all foreign jurisdictions.
• Deferred taxation: Generally, subsidized payouts are subject to the principle of deferred taxation under § 22 Nr. 5 EStG, provided Germany retains the right of taxation.

Outlook from 2027: Open Questions Regarding the Subsidy Procedure

While the core principles are established in the statutory text of the Retirement Provision Reform Act (AVRG, BGBl. 2026 I No. 156), the practical administration for cross-border cases will only take shape once the market launches in 2027. How the Central Allowance Authority for Retirement Assets (ZfA) technically implements the reporting procedure for changes of residence will be detailed in forthcoming Federal Ministry of Finance (BMF) circulars and implementing ordinances.

Currently, the following key points apply to all savers:

• Administrative practice from 2027: The exact reporting deadlines and digital interfaces between brokers, the ZfA, and tax authorities for account holders residing abroad will be established progressively.
• Binding authority: Legal certainty is provided exclusively by official administrative guidelines published in the Federal Law Gazette (Bundesgesetzblatt) or Federal Tax Gazette (Bundessteuerblatt).
• Country-specific details: Specific questions regarding target countries, particularly cross-border commuter situations, remain subject to individual review until final clarifications are issued.

Your Next Steps: Why Every Case Requires Individual Assessment

What moving abroad means for your pension investment depot depends on a clear sequence of factors: First, the general baseline rule applies, ensuring your invested depot assets always remain protected. Crucial for your subsidy balance are your specific destination country (EU/EEA or third country), the exact timing of your relocation (accumulation phase or withdrawal phase), and the decision whether to continue contributing or place the depot on hold.

This is where general guides and automated calculators reach their limits: no standard article can definitively evaluate the tax interactions of a specific double taxation agreement alongside your individual residency status.

1. Analyze your status: Clarify your exact destination country and verify whether it falls within the EU/EEA area.
2. Calculate your subsidy balance: Determine the total amount of allowances and tax deductions accrued to date.
3. Seek expert guidance: Have your individual cross-border relocation independently reviewed before modifying or terminating any contracts.

To verify your personal pension arrangements with legal certainty before moving, the independent advisory matchmaking service from Vorsorgedepot-Lotse offers a direct and reliable route to licensed experts who can assist you with your plans.

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