🇿🇦 Withdrawing a South African Retirement Annuity from Ireland: SARS Tax, the Treaty and Irish Tax

Can you withdraw your retirement annuity while living in Ireland?

• The three-year rule. Since 1 March 2021 a member who has been non-resident for an uninterrupted period of three years or longer can take the whole RA before retirement age. The clock counts from the date you ceased to be South African resident, not from when you finished the SARS paperwork, and the old financial emigration route through the Reserve Bank no longer applies (FinGlobal, August 2026). How that date is fixed is in our guide to ceasing South African tax residency.
• The two pots. Since 1 September 2024, new contributions go one third to a savings component and two thirds to a retirement component; everything saved before then is the vested component. The savings component can be withdrawn once per tax year, with a minimum of R2,000 (FinGlobal, August 2026), and the withdrawal is taxed at your South African marginal rate (Allan Gray, May 2026). The retirement and vested components stay locked until the three years or retirement.
• At retirement (from 55). You can take up to a third of the vested component and any part of the savings component in cash. The rest, and the whole retirement component, buys an income annuity, unless the amount that would have to buy an annuity is no more than R360,000 (from 1 March 2026, up from R247,500), in which case it can all be paid in cash (Old Mutual; Sanlam).
• What the fund asks for. SARS confirmation that you're non-resident, a clean tax compliance status, and a SARS tax directive, which tells the fund how much tax to deduct before it pays you. Outstanding returns can hold up the directive. Moving retirement fund money abroad goes through an Approval International Transfer (AIT) on eFiling (FinGlobal); the process is in the cessation guide.

How does South Africa tax the withdrawal?

• The tables are cumulative. SARS works out the tax on each lump sum by adding it to the lump sums you've already had: withdrawal benefits since 1 March 2009, retirement lump sums since 1 October 2007 and severance benefits since 1 March 2011 all count, whichever table applies. So an earlier withdrawal pushes a later withdrawal, or your eventual retirement lump sum, into higher bands.
• Savings-pot withdrawals are different. They're taxed as income at your marginal rate, not on either table. For 2027 South Africa's brackets start at 18% and reach 45% above R1,878,600, with a primary rebate of R17,820 (SARS), so a small withdrawal by someone with no other South African income can come out with little or no tax.
• Waiting changes the table, not just the timing. R500,000 taken in cash at retirement pays nothing under the retirement table; the same R500,000 taken now under the three-year rule pays R85,050.

Does the treaty let South Africa tax it?

• The other income argument. Allan Gray's view is that pension and provident fund benefits fall under the pensions article because they come from past employment, while retirement annuities are personal products, so a withdrawal falls under the other income article (Allan Gray, May 2026). In the Irish treaty that's Article 22(1): income not dealt with elsewhere "shall be taxable only" in the country of residence. You tell the fund up front that you want the treaty applied, and SARS uses its discretion; if it refuses, the fallback is relief in Ireland.
• Why the Irish treaty is harder. Many treaties limit the pensions article to pensions "in consideration of past employment". Article 18(1) of the Irish treaty has no such limit: it covers "pensions and other similar remuneration and annuities". A lump sum isn't an "annuity" as Article 18(2) defines it (a stated sum paid periodically), but SARS can argue that an RA payout is a pension or similar remuneration, which South Africa may tax under Article 18 (treaty text).
• The remittance clause. If you're taxed in Ireland on the remittance basis and South Africa gives you treaty relief, Article 23(5) limits that relief to the part you bring into Ireland. A non-domiciled resident can't claim South African relief on money that never reaches Ireland.
• Annuity income and savings withdrawals. SARS's RST01 form asks for a directive reducing the South African tax under a treaty on a pension, an annuity or a savings withdrawal benefit, with Revenue certifying your Irish residence on the form itself (SARS RST01). Allan Gray says the directive is valid for three tax years while you stay resident in the same country (Allan Gray, May 2026). Under the Irish treaty, South Africa normally keeps its right to tax a pension, so expect a credit in Ireland rather than a South African exemption.

How does Ireland tax a South African retirement payout?

• Why this matters for South African funds. The two-pot savings component lets any member withdraw every tax year, for any reason. The three-year emigration withdrawal in our example is itself access before retirement, and pension, provident and preservation funds paid out on resignation long before 2024, so the question isn't only a two-pot one. Revenue's examples of disqualifying access are withdrawals for "certain financial needs, purchasing a home or other purposes unrelated to retirement". It hasn't named South African funds or said how a payment from a fund that fails the test is taxed. For foreign lump sums paid before 2023, its stated position is that they were taxable in full as foreign income, apart from a concessionary €200,000 exemption that doesn't apply to payments from 2023. If your fund is outside section 200A, expect Revenue to look at the payout as foreign income taxed at your marginal rate, with USC.
• If you're not Irish-domiciled (most South Africans here aren't), you're taxed only on what you bring into Ireland. The manual says so for section 200A lump sums, and the same remittance basis applies to foreign income generally. See the remittance basis guide.
• Credit for the South African tax. Where the treaty lets South Africa tax the payment, Ireland credits the South African tax against the Irish tax on the same income (Article 23(1)). Under section 200A, a lump sum within the €200,000 tax-free amount has no Irish tax to credit against, so the SARS deduction is the final cost. Between €200,000 and €500,000, Revenue's manual says no reliefs, deductions or tax credits may be set against the 20% charge, and it doesn't say whether a treaty credit is allowed there.
• Pension and annuity income from South Africa is taxed in Ireland like any foreign pension: income tax and USC, but not PRSI (Revenue). Your lump sums count towards the same €200,000 lifetime amount as Irish ones; see pension lump sum tax in Ireland.
• It goes on Form 11. Revenue's manual says a section 200A amount belongs on your Form 11 for the year it's paid, and foreign income above the Form 12 limits makes you a chargeable person anyway. See our Form 11 guide.

Worked example: a nurse in Cork withdraws an RA after three years

Starting data (assumptions): Sipho is a clinical nurse manager in Cork earning €72,000 in 2026, so his top rates are 40% income tax and 8% USC. He's Irish resident and still South African-domiciled. He ceased South African residence on 1 July 2022, the date recorded with SARS, when his family joined him and the family home in Johannesburg was sold, so his three years ran out on 1 July 2025. His RA is worth R1,500,000 in November 2026. He stopped contributing in 2021, so it's all in the vested component apart from the small amount moved ("seeded") into his savings component in September 2024, which we ignore to keep the numbers simple. He has had no earlier lump sums from any fund, South African or Irish. We use €1 = R20; Revenue would use the rate on the day of payment.

The South African figure is fixed by the table. The Irish figure turns on one question Revenue hasn't answered for South African funds: is the RA a foreign pension arrangement, given that it allows withdrawals before retirement? If it is, the R371,700 is Sipho's whole tax and a treaty claim could take it to nil. If it isn't, removing the SARS tax barely changes the total: Ireland grosses the €56,415 back up by the credit, so he pays €18,585 in South Africa plus about €15,928 here, €34,513 in all, against €36,000 to Ireland alone with treaty relief. If Revenue also grossed up the USC base, the two totals would be the same. Leaving the money outside Ireland defers the Irish question rather than answering it, because it becomes taxable when it's brought in while he's still resident.

What about pension funds, provident funds, the GEPF and living annuities?

Former public servants should check their nationality as well as their residence. A nurse or teacher who has become an Irish citizen and lives here falls into Article 19(2)(b), which gives the GEPF pension to Ireland alone; South Africa should then stop taxing it once SARS accepts the treaty claim. GEPF lump sums are a separate question for a South African practitioner.

When should you take the money?

• Withdraw now: the withdrawal table applies to everything above R27,500, and the Irish question above applies in the year it's paid.
• Wait until 55: the first R550,000 of retirement lump sums is tax-free in South Africa, but two thirds of the vested component and the whole retirement component must buy an annuity, which both countries then tax as income for the rest of your life.
• Leaving Ireland anyway: section 200A applies only if you're Irish resident when the lump sum is paid. If you're moving on, the order of the move and the withdrawal matters; ask before you do either.
• Spread the savings pot: one savings withdrawal per South African tax year, from R2,000, keeps each one in lower South African brackets. The Irish treatment follows the fund it comes from.

What Revenue actually asks for

• The fund's benefit statement and the SARS tax directive showing the gross lump sum and the tax deducted.
• The IRP5 or tax certificate the fund issues, as proof of South African tax for the credit.
• The fund rules or a letter from the administrator describing the components and when members can access them.
• Bank records of every transfer into Ireland from the account the money was paid into, if you're not Irish-domiciled. Keep the lump sum in its own account so it isn't mixed with capital you had before you arrived.
• Revenue's certification of your Irish residence: on the RST01 form itself for an annuity or savings-withdrawal directive, or a certificate of residence if SARS asks for one on a lump sum directive.

Where do you start?

Get three facts on paper: the date your South African residence ended, what your fund is worth in each component, and whether you're Irish-domiciled. Ask your South African practitioner for the directive figure, and ask an Irish adviser how Revenue is likely to treat the fund, before you sign the withdrawal form. Leave the money in a separate account until both answers are in.

Related reading

• Ceasing South African tax residency from Ireland: routes, exit tax, RA
• Ireland–South Africa tax treaty: who taxes what
• Tax for South African workers in Ireland
• Pension lump sum tax in Ireland: the €200,000 lifetime limit
• The remittance basis for non-domiciled residents
• USC in Ireland explained
• Your Nigerian pension (RSA) from Ireland
• Tax guides by nationality

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