The Trans-Tasman Retirement Savings Portability Scheme: Moving Super Between Australia and New Zealand KiwiSaver

For Australians who have worked in New Zealand at some point in their career and accumulated a KiwiSaver balance, or for New Zealanders who have lived in Australia and built up Australian superannuation, the question of whether to consolidate retirement savings in one jurisdiction has been simplified — though not solved — by the Trans-Tasman Retirement Savings Portability Scheme. Operational since 1 July 2013 under bilateral arrangements between the Australian and New Zealand governments, it is the only formal portability arrangement Australia has with any other country's retirement system. For trans-Tasman retirees and dual-citizen members, it provides a structured pathway to consolidation that transfers from other foreign retirement systems — UK pensions, US 401(k)s — must navigate independently under separate Australian tax law provisions.

The scheme operates in both directions. A KiwiSaver account holder who has permanently emigrated to Australia can transfer their KiwiSaver balance to a participating Australian super fund. An Australian super member who has permanently emigrated to New Zealand can transfer their Australian super balance to a participating KiwiSaver scheme. In both directions, the conditions are similar: the member must have permanently emigrated; the receiving fund must be a participating scheme (most large APRA — Australian Prudential Regulation Authority — regulated Australian funds participate; SMSFs — self-managed super funds — typically do not; major NZ KiwiSaver providers participate); and the transferred amount counts against the receiving country's contribution caps. The transfer itself is tax-neutral when conditions are met — there is no immediate tax event in either jurisdiction on a properly executed transfer.

The non-concessional contributions cap — the limit on after-tax money you can put into superannuation — is where the scheme's flexibility meets Australian regulatory reality. For Australians receiving a KiwiSaver transfer, the amount counts as a non-concessional contribution. The non-concessional contributions cap for FY2025-26 is $120,000 per year, with a bring-forward arrangement allowing up to $360,000 over three years for members under 75 whose Total Super Balance is below the relevant threshold (ATO, ato.gov.au/.../non-concessional-contributions-cap). For substantial KiwiSaver balances — KiwiSaver members who have contributed at the maximum rate for many years can easily reach NZ $400,000 to $700,000 or more — the cap forces multi-year staging. A NZ $500,000 KiwiSaver transfer, approximately AUD $460,000 at recent exchange rates, would exceed the $360,000 bring-forward cap in a single year, requiring at least two transfers spread across different financial years.

The Total Super Balance threshold can preclude the transfer entirely. If an Australian receiving member's Total Super Balance is $2.0 million or more at the prior 30 June, the non-concessional contributions cap is nil for that financial year (ATO, ato.gov.au/.../non-concessional-contributions-cap: "$2 million from 2025–26"). A KiwiSaver transfer of any size would be excess, with associated earnings taxed at marginal rates plus the excess contribution charge. For Australians with substantial existing super and a meaningful KiwiSaver balance, this constraint often requires careful balance management — typically by commencing a pension and drawing down over time — before the transfer can proceed cleanly.

Source-country preservation rules continue to apply after transfer, and this is one of the scheme's quietly important features. Australian preservation rules continue to apply to Australian-source amounts after transfer to KiwiSaver — a member who transferred Australian super to KiwiSaver cannot use New Zealand's age-65 access pathway for those funds if Australian preservation hasn't been met. NZ preservation rules continue to apply to NZ-source amounts after transfer to Australian super — NZ-source amounts in an Australian fund are accessible at age 65 under NZ rules, or under other Australian conditions of release, whichever is later. The dual-rule treatment is recorded by the receiving fund and tracked through the member's account for the life of that balance.

The bilateral-only nature of the scheme is the constraint that most surprises retirees with multi-country histories. NZ-source amounts in Australian super cannot be transferred onward to a UK pension under QROPS arrangements, to a US retirement account, or to any other foreign system. Australian-source amounts in KiwiSaver cannot be transferred to any foreign retirement system except Australia. For retirees who have lived in three or more countries during their working life, the Trans-Tasman scheme provides only the AU-NZ leg. UK pensions arriving in Australia must use separate ITAA 1997 provisions; US retirement accounts have no formal Australian portability pathway.

The SMSF restriction is the operational catch most likely to surprise retiring SMSF holders with a KiwiSaver balance to consolidate. Most SMSFs are not participating funds for the Trans-Tasman scheme — the receiving fund must be APRA-regulated. For retirees who hold an SMSF and want to bring across their KiwiSaver, the typical pathway involves first transferring the KiwiSaver to an APRA-regulated fund, then rolling that balance to the SMSF — though this adds complexity, potential fees, and subjects the second rollover to standard Australian rollover rules.

What does staging a KiwiSaver transfer within the NCC cap look like?

Helen, 63, permanently emigrated from New Zealand to Australia in 2022. She has a KiwiSaver balance of NZ $420,000 — approximately AUD $386,000 at a 0.92 exchange rate. Her existing Australian super balance at 30 June 2025 is $1,550,000, well below the $2.0 million nil-NCC threshold, and she is under 75. She can access the full 3-year bring-forward in FY2025-26: a maximum of $360,000. To transfer her full KiwiSaver balance, Helen staggers the transfer: AUD $360,000 in FY2025-26 using the bring-forward arrangement, then the remaining AUD $26,000 in FY2028-29 once the three-year bring-forward window has reset. The transfer is tax-neutral in both jurisdictions when properly structured. Once the balance is in her Australian fund, NZ preservation rules continue to apply to the NZ-source component — accessible at age 65 under NZ rules, or other Australian conditions of release, whichever is later.

What happens when a Total Super Balance above threshold blocks the transfer?

Robert, 67, also moved permanently from New Zealand to Australia and has a KiwiSaver balance of NZ $280,000 (approximately AUD $258,000). His existing Australian super balance at 30 June 2025 is $2,150,000 — above the $2.0 million TSB nil-NCC threshold (ATO, FY2025-26). His non-concessional contributions cap for FY2025-26 is nil. Any KiwiSaver transfer would be treated as excess non-concessional contributions, with associated earnings taxed at marginal rates plus the excess contribution charge. Robert's practical options are to maintain the KiwiSaver in New Zealand while drawing down his Australian super over coming years, revisiting the transfer once his Total Super Balance naturally falls below $2.0 million through minimum pension drawdowns; or to formally review his balance management strategy with an adviser. The transfer cannot simply proceed while his balance remains above threshold — the NCC cap mechanics apply regardless of the source of the funds.

Sources

• Australian Taxation Office (ATO) — Non concessional contributions cap