I am an Australian permanent resident with a healthy superfund balance, built up mostly from contributions by myself and by the business I owned. I am looking to retire in the Netherlands, where I was born. I have been unable to find out if the Dutch tax office will have a right to tax my super income when I withdraw (either lump sums or regular income) after I am 60. An international tax adviser and a person at the Dutch tax office informed me that I will have to pay regular income tax rates over my pension coming from abroad. However, 15% tax has already been paid in Australia when the money went into super, which is quite unique in the world. I want to find out whether the ATO has any information that may help me find out if I will indeed be taxed again on my super savings when I move to the Netherlands?
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I have recent experience on this. Your Australian super does NOT qualify as a pension in NL. I have a tax ruling in NL on this. You will be taxed as an asset. The capital balance in your fund will be taxed in box 3 as any ordinary asset. This will be about 1.7% per year until about 2026, when you will be taxed differently but still as an asset (you can look up the new rules on line for box 3 tax in the future as NL is making a major change from deemed earnings to actual earnings. Now even if you were taxed as pension income you would pay 19% up to 35k euros per year and 37% up to about 68k euros and 49.5% after that.
No, it isn't fair at all, and is costing me a ton of tax here, but that was the private ruling. The reason is that under Section 3.82 of the relevant act, if ANY tax is paid on contributions or income, it is not considered a Dutch pension.
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An international tax adviser and a person at the Dutch tax office informed me that I will have to pay regular income tax rates over my pension coming from abroad.
They would know more than we would about Dutch tax.
There may be a deduction for the part of the pension arising from your own personal contributions - you would need to ask them about that.
However, 15% tax has already been paid in Australia when the money went into super
But that is employer contributions tax - has relevance to the taxabity of pensions paid to AUS residents, but not to treatment by foreign tax offices.
For example, a AUS resident receiving a Japanese age pension was adamant that it was tax free in Japan - but that did not stop that pension being taxable in AUS.
Different countries have different tax laws, but they mostly agree that pensions should only be taxed in the country of residence.
Thanks for your response and insight. I guess I should have mentioned that I had my own company and made personal contributions both from my company and in later years from personal funds. I'm trying to get an overview from my superfund of the different contributions so I can argue which parts shouldn't be taxed again or at least I can deduct the tax already paid over that part.
I have recent experience on this. Your Australian super does NOT qualify as a pension in NL. I have a tax ruling in NL on this. You will be taxed as an asset. The capital balance in your fund will be taxed in box 3 as any ordinary asset. This will be about 1.7% per year until about 2026, when you will be taxed differently but still as an asset (you can look up the new rules on line for box 3 tax in the future as NL is making a major change from deemed earnings to actual earnings. Now even if you were taxed as pension income you would pay 19% up to 35k euros per year and 37% up to about 68k euros and 49.5% after that.
No, it isn't fair at all, and is costing me a ton of tax here, but that was the private ruling. The reason is that under Section 3.82 of the relevant act, if ANY tax is paid on contributions or income, it is not considered a Dutch pension.
Thanks for sharing your valuable insights! I currently live in The Netherlands and have a super in Australia. My Dutch accountant has considered my Australian Super as an asset as the balance of my Dutch super isn't considered an asset either. Taxes come into play as soon as a Dutch super is being paid out. As I am looking at buying some land, I am considering having my Australian super being paid out (qualifies for tax free distribution) to my Australian bankaccount. If I understand the ruling you've mentioned correctly, the lump sump amount that will be paid out isn't taxed at progressive income tax rates but will need to be taxed in box 3 as an ordinary asset. Did I understand this correctly? Is the ruling you mentioned a private ruling or a general one that you could share (I can then share this with my Dutch accountant who is struggling to understand the Australian super system). Could you pls name the relevant act (Section 3.82) you're referring to - I can probably use that in my discussion with the Dutch accountant as well. Much appreciated!
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