Can I keep my IRA or Roth IRA after moving back to Europe?
Short answer: Yes, you can keep a US IRA or Roth IRA when moving to Europe, but its treatment varies by country. While traditional IRAs are generally recognized as tax-deferred by treaties, Roth IRAs are not always granted tax-free status in Europe (e.g., in Germany or France). Additionally, many US brokers will restrict your ability to trade within the account once you move.
Written and reviewed by Anthony Walsh, Selanis. Last reviewed 2026-10-06.
Why it works this way
Tax treaties usually protect the tax-deferred growth of a Traditional IRA. However, the Roth IRA is a newer structure and is not explicitly mentioned in many older treaties. This means some European countries may view a Roth IRA as a regular taxable brokerage account, taxing the dividends and capital gains annually even if no distribution is taken.
Brokerage access is a significant hurdle. Many US firms (like Vanguard, Fidelity, and Schwab) may restrict accounts for EU residents to 'liquidation only' due to MiFID II regulations. This means you can sell what you have but cannot buy new US-domiciled ETFs or mutual funds, which can be problematic for a decades-long retirement strategy.
If you are a 'covered expatriate' (a long-term green card holder meeting certain wealth or tax thresholds), your IRA is treated as fully distributed on the day before you expatriate for US tax purposes. This 'deemed distribution' triggers immediate US tax on the entire balance, even if you don't actually withdraw the funds.
The expensive mistake: Assuming a Roth IRA is tax-free in your home country
Just because the US doesn't tax Roth distributions doesn't mean France, Germany, or Finland won't. Without specific treaty protection, your home country may tax the annual growth or the eventual withdrawals, effectively negating the Roth's primary benefit. Always check the specific treaty language for 'pensions'.
What to do
- Check your home country's view on Roth IRAs — Research whether your destination country recognizes the tax-exempt status of a Roth IRA under the 'pensions' article of the tax treaty.
- Consolidate accounts before moving — It is easier to manage one or two IRA accounts from abroad than several small ones. Consider consolidating while you still have US residency.
- Move to a cross-border-friendly custodian — Consider moving your IRA to a firm like Interactive Brokers that is built to service international clients and EU residents.