Retirement planning is becoming truly international.

From Dublin to Amsterdam, a rising number of Portugal-based expats are moving their pensions into pan-European structures known as IORPs, seeking the flexibility their home systems lack.

Financial advisers at deVere Group, which works with more than 80,000 expatriate clients worldwide, report that transfers are accelerating as mobile workers look for tax efficiency and control.

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“More and more Irish and Dutch nationals are recognising the structural disadvantages of keeping pensions in their home countries,” says James Green, Director of deVere Europe.

“IORPs in Malta deliver solutions that reflect modern, mobile lives. Over the past two years we’ve seen double-digit growth in transfers from both Ireland and the Netherlands.”

His colleague Jake McLaughlin, Director at deVere Portugal, agrees: “The demand is surging.

“People have watched friends constrained by domestic pension rules and they want options. We’re seeing strong inflows into IORPs because they fit Portugal’s tax system and the flexibility retirees expect.”

Rather than leaving funds under domestic regimes, Irish and Dutch citizens are increasingly relocating pension pots to European hubs such as Malta—especially when settling in Portugal, where the tax environment rewards careful planning.

Why the change is happening

Ireland’s pension regime is among Europe’s most restrictive.

The Standard Fund Threshold caps tax-efficient savings at €2 million; anything above draws a 40 percent charge. Only a quarter of a pot can be taken tax-free up to €200,000, with steep taxes beyond, and annual drawdowns are compulsory from age 61. Once assets enter an ARF, they cannot be moved again.

The Dutch system presents its own hurdles: most occupational plans require lifetime annuities and allow only minimal lump sums, leaving little room for flexible income planning.

Malta’s IORP structures upend those limits. Members can take up to 30 percent of their pension tax-free with no lifetime cap, begin withdrawals at 50, and choose whether or not to draw income each year.

Portugal generally taxes lump sums as investment income or, in some cases, capital gains, but its double-tax treaties with Malta help soften the impact.

Portugal’s appeal

Portugal’s climate and lifestyle remain a strong draw, but the financial framework often seals the deal.

The updated ‘NHR 2.0’ regime is less generous than the original Non-Habitual Resident programme, yet it still rewards those who structure pensions through IORPs.

“Expats here are highly informed,” McLaughlin adds. “They understand that careful cross-border planning lets them shape income streams around lifestyle goals instead of being locked into domestic schedules.”

Why Malta stands out

Malta’s IORP II framework—supervised by the Malta Financial Services Authority and based on EU directives—is widely seen as Europe’s benchmark.

Assets are ring-fenced in trust, beneficiaries inherit efficiently, and payments can be made in the retiree’s local currency. Where neither member nor heir is resident in Ireland or the Netherlands, those countries’ inheritance taxes generally do not apply.

With inflation eating into returns and market volatility unsettling savers, the ability to choose phased withdrawals, lump sums or annuity-style income is a decisive advantage.

Real-world impact

Consider a €2 million pension. In Ireland, only €200,000 can be taken tax-free; the rest is heavily taxed and may face inheritance charges.

Malta allows a tax-free release of about €600,000 and efficient transfer to heirs, with no lifetime cap. Dutch residents can achieve similar benefits when moving large occupational pensions.

James Green points out that many Irish defined-benefit schemes are under pressure and Dutch corporate plans face comparable funding gaps.

“Employer covenants are weaker, payouts are at risk, and that is driving urgency to explore cross-border solutions before options narrow,” he says.

Complex but worthwhile

Not every pension can be moved. Irish personal pensions, PRSAs and state benefits must remain in Ireland, and Dutch state pensions cannot be transferred. Careful analysis of treaty rules and long-term residency plans is essential.

Still, for those with significant occupational pots, the case is compelling. “The key is understanding your personal tax residence and how the double-tax treaties work,” McLaughlin explains. “Done properly, the rewards are significant.”

Planning for heirs

Inheritance rules add another incentive. Irish heirs can face a 33 percent capital acquisitions tax, and Dutch beneficiaries may pay up to 40 percent depending on relationship and amount. Malta-based IORPs, treated as non-Irish and non-Dutch assets for non-residents, often avoid those charges entirely.

For Irish and Dutch expatriates alike, pensions are no longer just savings accounts, they’re instruments of independence and long-term security, and broader freedoms can be unlocked by international retirement planning solutions.

If you have any questions, you can email Jake: jake.mclaughlin@devere-portugal.pt