AOW, pension and tax in Ireland: the €25,000 threshold and the USC exemption
The tax treaty with Ireland allocates pensions and AOW to Ireland, up to a total of €25,000 a year; above that the Netherlands may tax too. The Irish side is milder than it looks: the AOW is exempt from the Universal Social Charge there, and over seventy or with a medical card you pay a lower USC. The ABP pension usually stays at home, and for foreign income there is the remittance basis.
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If you live in Ireland, Ireland as a rule taxes your pension and your AOW. But the tax treaty with the Netherlands has one number that decides everything: €25,000.
Three things to know up front:
- If your pensions, annuities and social security pensions together exceed that amount, the Netherlands may tax too.
- The Irish side is milder than the rates suggest. The AOW is exempt there from the Universal Social Charge (USC), a second levy on income alongside income tax. Whoever is 70 or older, or has a medical card, pays a lower USC on an income up to €60,000.
- The trap is in the occupational pension: that does fall under the USC. And a pension from government service as a rule stays taxed in the Netherlands, but still counts towards the threshold.
Who taxes what?
The treaty settles it in articles 17 and 18.
| Income | Who may tax | Article |
|---|---|---|
| Pension, annuity and AOW, together up to €25,000 gross a year | Ireland only | 17, paragraph 1 |
| Pension, annuity and AOW, together above €25,000 | Ireland, and the Netherlands may tax too | 17, paragraph 2 |
| Lump sum or other non-periodic payment | the Netherlands too | 17, paragraph 3 |
| Pension from government service (for example ABP as a civil servant) | the Netherlands only, unless you are a resident and an Irish national | 18, paragraph 2 |
Two details make the difference. The threshold counts everything together, including a government pension. And a pension or annuity counts as Dutch if you received a tax advantage in the Netherlands for the contributions or the entitlements. Above the threshold both countries tax. How double taxation is then avoided has to be worked out per situation.
What is milder on the Irish side?
The Universal Social Charge is a second levy on income, alongside income tax. Whoever has €13,000 or less a year doesn't pay it. Above that you pay on your whole income.
| USC 2026 | Rate |
|---|---|
| up to €12,012 | 0.5% |
| €12,012.01 to €28,700 | 2% |
| €28,700.01 to €70,044 | 3% |
| above €70,044 | 8% |
| 70 or older, or with a medical card, income up to €60,000 | at most 2% |
Payments from Social Protection, the Irish department for social welfare payments, and similar payments from abroad are exempt. So the AOW is too. An occupational pension does fall under it.
The reduced USC for those under 70 requires a full medical card. A GP visit card, which only covers visits to the GP, doesn't count. For whoever comes to Ireland with an S1 and gets a medical card that way, that is worth having. How that works is covered in healthcare in Ireland.
What is the remittance basis, and for whom?
Whoever is tax resident in Ireland but not domiciled there pays tax on foreign income only to the extent that they bring it into Ireland. Think of interest, dividends, foreign rent or a foreign pension. Domicile is the country where you intend to stay permanently. Whoever moves to Ireland for a number of years often keeps their Dutch domicile.
Note: as with Malta, the Netherlands may then tax the pension you don't bring to Ireland (article 22 paragraph 4 of the tax treaty).
Revenue, the Irish tax authority, names the limits in its manual:
- salary for work in Ireland never falls under it;
- a transfer from an account where income and capital are mixed counts as income first;
- savings from income from before 1 January of your first Irish year remain untaxed by established practice.
That calls for separate accounts, set up before the move. How this connects with the scheme for assigned employees is covered in SARP and the remittance basis.
What does the Netherlands not let go of?
Your AOW accrual stops on the day you leave: for every year you are not insured, 2% comes off your AOW. You can repair that with the SVB's voluntary insurance, but only if you apply within a year of the end of the compulsory insurance (usually the day you leave). How that works is covered in your AOW accrual stops when you leave. Whether your AOW payment itself changes depends, according to the SVB, on your situation and on the country. Pass on your new address yourself, because the municipality no longer does that.
If you built up a pension or an annuity in the Netherlands with a tax advantage, or have a substantial interest, you get a protective assessment after the return for your year of emigration: an assessment with which the Netherlands records its tax claim when you leave. You usually don't have to pay it for ten years, as long as you keep to the rules, for example by not commuting your pension. For pension and annuity you can then ask for remission. For a substantial interest the assessment stays valid indefinitely.
Work out the threshold before you let the pension start. Below €25,000 only Ireland taxes, with the USC exemption for the AOW. Above it both countries tax. An occupational pension you commute in one go the Netherlands may tax in any case, and it also makes the protective assessment payable.
The sum you make before leaving
Add up your gross pensions, annuities and AOW. If you stay below €25,000, the split is simple. If you go above it, or have a government pension, investments or a private limited company, work it out with a tax adviser who knows both countries, before you build other decisions on it.
In Vertrekklaar this is phase 2 of 5 of the journey, step 2.2: the same steps, but for your situation — in your order, tickable, and with the deadlines watched. See the whole journey to Ireland or go straight to step 2.2 in the open plan.
What this means for your numbers →
What this rests on
The facts in this article come from these official pages. Rules change. When in doubt, go by the source, not this article.
- Tax treaty Netherlands-Ireland — articles 17, 18 and 22 paragraph 4 — wetten.overheid.nl
- Citizens Information — the Universal Social Charge and the exemptions — citizensinformation.ie
- Revenue — domicile and the remittance basis — revenue.ie
- Citizens Information — tax on coming to Ireland, with the remittance basis — citizensinformation.ie
- SVB — your AOW if you go to live outside the Netherlands — svb.nl
- Belastingdienst — protective assessment on emigration — belastingdienst.nl
- Revenue — Tax and Duty Manual 05-01-21A, the remittance basis — revenue.ie
- SVB — the conditions for voluntary insurance for the AOW — svb.nl
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