Pension portability when leaving Germany

Contributions are credited to your German pension account regardless of where you live in retirement. The pension itself is paid out wherever you reside, with some technical rules around bank accounts and proof of life.

Inside the EU/EEA/Switzerland: contributions in different member states are aggregated under EU regulation 883/2004, no contributions are 'lost', and the minimum vesting period can be met across countries.

Outside the EU: depends on whether Germany has a social-security agreement (Sozialversicherungsabkommen) with the country. With agreement: similar logic to EU. Without agreement: you only collect what you funded yourself; you can sometimes claim a one-off reimbursement of your contributions after at least 24 months outside the EU.

bAV stays in Germany. The contract continues, the assets stay where they are, and payout happens according to the contract, usually as a German-source pension at retirement.

If your new country of residence has a Double-Taxation Agreement (DTA) with Germany, the DTA decides whether Germany or the new country gets to tax the future payout. Most DTAs assign occupational pensions to the country of residence at the time of payout.

What rarely works well: trying to transfer bAV abroad. Cross-border bAV transfers exist on paper but are administratively heavy and almost never beneficial for a typical employee.

Riester is built around German tax residency. When you leave the EU/EEA and the foreign country has no special agreement, the subsidies and tax benefits you received can be reclaimed by the state (Rückforderung der Zulagen).

Inside the EU/EEA: the subsidy is generally protected since the 2018 'Betriebsrentenstärkungsgesetz' changes, but the product still becomes harder to manage from abroad.

Practical view: Riester rarely survives a relocation well. For mobile expats, the case for funding new Riester contributions today is weak.

Rürup is a pure pension product, you cannot withdraw capital, you cannot terminate it for cash. The contract simply continues, paid in or paused, until retirement.

If you leave Germany, the contract stays, and the pension is paid wherever you live. Tax treatment of the future payout follows the DTA with your new country.

Rürup's tax advantage is fully realised only if you have many years of high taxable income in Germany. For shorter German stays, the math often does not justify the lock-in.

Wrapper-specific. Some providers continue the contract for non-residents but stop accepting new contributions; some require relocation to specific countries; some apply different tax treatment on payout.

The German tax case (12 years + age 62 'half-rate') depends on you being a German tax resident at payout. If you're not, your new country's tax rules apply, sometimes better, often worse.

Before you sign one of these as an expat with a real chance of moving, the question must be: how does this wrapper behave in 5 candidate destination countries?

The most portable structure. Most German brokers can keep your assets after you leave, though some require you to transfer to another broker.

Vorabpauschale and KESt stop applying the moment you stop being a German tax resident. Your new country's rules take over, most countries tax capital gains on disposal, not annually.

Watch out for: PFIC rules (US), beneficial ownership rules (some Asian markets), and the need to physically be the registered holder of the depot.