What happens to my UK pension?
You can keep your UK pensions when you move to the US. Unlike in Australia or Canada, your UK State Pension keeps rising each year there. But the US taxes UK pensions under treaty rules that are technical, and moving a pension across is rarely possible.
In 30 seconds
- Your UK State Pension is paid in the US and gets the yearly increase, because the US is on GOV.UK’s list of countries that get it
- Since 6 April 2026 you can only pay voluntary Class 3 National Insurance for time abroad, and only with 10 years’ UK residence or contributions
- Under the treaty, UK pensions paid to a US resident, including the State Pension, are generally taxed in the US. Take regulated cross-border advice before moving or cashing in anything
The State Pension keeps rising in the US
You can claim your UK State Pension while living in the US. It only goes up each year if you live in the EEA, Gibraltar, Switzerland or a country with a social security agreement with the UK (except Canada and New Zealand). The US is on GOV.UK’s list of countries where the annual increase is paid, so your pension rises as it would at home.
You choose one country to be paid in: a bank in the US, or a bank or building society in the UK.
Voluntary National Insurance after April 2026
Gaps in your National Insurance (NI) record reduce your State Pension. The rules for paying voluntary contributions for time abroad changed on 6 April 2026:
- You can no longer pay the cheaper Class 2 contributions for time abroad
- You can pay Class 3 (£18.40 a week in 2026/27) if you lived in the UK for 10 years in a row, or paid 10 years of qualifying NI in total
- If you applied before 6 April 2026 you may still use the old 3-year rule, if you also apply for 2026/27 and pay by 5 April 2027
- You apply with form CF83. Check your NI record and forecast on GOV.UK before you leave
The US–UK social security agreement
- If your UK employer sends you to the US for a limited period (usually up to 5 years), you can stay in UK National Insurance instead of paying US Social Security tax. Get a certificate of coverage before you start
- If you are hired locally in the US, you pay US Social Security and Medicare tax (FICA) like other workers
- You need 40 US “credits” (about 10 years of work) for a US Social Security pension. If you have some US credits but not enough, UK NI years can be counted to help you qualify for a partial US pension
- The Social Security Fairness Act, signed in January 2025, repealed the WEP and GPO rules that used to cut some people’s US benefits, for benefits payable after December 2023
UK workplace and personal pensions
- You can leave them where they are. They stay invested in the UK
- You can usually take money from them from age 55, depending on the scheme’s rules. The minimum age rises to 57 from 6 April 2028 for most people
- Tell each provider your new address and check they can pay into a US account
- From 6 April 2027, most unused pension funds will count towards your estate for UK Inheritance Tax
How the US taxes UK pensions
Once you are a US tax resident, the UK–US treaty (Articles 17 and 18) decides who taxes what. In outline:
| Pension | Usual treatment under the treaty |
|---|---|
| UK workplace or personal pension income | Taxable only where you live, so in the US. You can claim relief from UK tax under the treaty |
| UK State Pension | Taxable only where you live, so in the US. GOV.UK says non-residents don’t usually pay UK tax on it |
| Growth inside a UK pension | Generally not taxed in the US until it is paid out, like a 401(k) |
| Lump sums | The treaty has special rules, including for the part the UK would treat as tax-free. This is technical: get advice before you take one |
The treaty can also let you keep paying into a UK pension you joined before the move, with US tax relief, if conditions are met; this part doesn’t apply to green card holders. US states don’t always follow the treaty (tax practitioners say California doesn’t), so your state may tax pension income differently. See Do I still pay UK tax?
Transferring to the US: usually not possible
To move a UK pension abroad without heavy UK tax, the receiving scheme must be a QROPS (a qualifying recognised overseas pension scheme). It’s up to you to check this.
| Rule | What it means |
|---|---|
| Not a QROPS | Your UK scheme may refuse, or you pay at least 40% tax on the transfer |
| Overseas transfer charge | 25% of the transfer, unless an exemption applies |
| Main exemption | You live in the same country as the QROPS (or it is your employer’s scheme), and you stay within your overseas transfer allowance |
| Moving again within 5 years | You may get a refund, or have to pay the 25%, depending on where you move |
US 401(k)s and IRAs aren’t set up to take UK transfers, so most people leave UK pensions where they are. Be very wary of offshore schemes sold to US residents.
Get advice and avoid scams
MoneyHelper gives free guidance on UK pensions. Paid advice should come from an adviser regulated in the UK and, for US investment advice, registered in the US. Be wary of anyone who contacts you out of the blue offering a transfer or early access: GOV.UK warns unauthorised payments before 55 can be taxed at up to 55%.
What to do next
- Get your State Pension forecast and NI record on GOV.UK
- Decide whether to pay Class 3 voluntary NI from the US
- Speak to a regulated UK–US adviser before taking any lump sum or moving a pension
Keep going
- GOV.UK: State Pension if you retire abroad: how your pension is affected
- GOV.UK: Countries where we pay an annual increase in the State Pension
- GOV.UK: State Pension if you retire abroad: how to claim and get paid
- GOV.UK: The new State Pension: what you’ll get
- GOV.UK: Voluntary National Insurance if you live or work abroad
- GOV.UK: Voluntary National Insurance rates
- Social Security Administration: US–UK social security agreement
- NAPA: WEP/GPO repeal has retroactive benefits (Dec 2024)
- GOV.UK: Early retirement, personal and workplace pensions
- GOV.UK: Increasing normal minimum pension age
- GOV.UK: Inheritance Tax on unused pension funds and death benefits
- GOV.UK: 2001 UK–USA Double Taxation Convention, as amended by the 2002 protocol (in force)
- Bright!Tax: The US–UK pension tax treaty provision taxpayers need to know about
- GOV.UK: Tax on your UK income if you live abroad
- GOV.UK: Transferring your pension to an overseas pension scheme
