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27
 
Jan
 
2025

Roth IRA, 401(k) in Europe: Are they available? Alternatives

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Imagine you’ve heard all about Roth IRAs and 401(k)s from American YouTubers or friends living in the United States, and you think, “Wow, that’s a great way to save for retirement with awesome tax benefits!”

Then you find out you’re living in Europe, and it’s not so simple to get those exact accounts.

Are they available in Europe?

The truth is, Roth IRAs and 401(k) plans are creatures of U.S. tax law. They’re only available to people who either reside in the U.S. or have U.S.-taxable income.

If you’re fully based in Europe, you can’t just open a Roth IRA at a random American brokerage and expect the same tax advantages.

So, what do Europeans do instead?

Alternatives in Europe

Thankfully, there are European replacements for retirement savings, and many countries have their own solutions. One key project at the European Union level is the Pan-European Personal Pension Product, often called the PEPP.

The idea behind the PEPP is to give people in Europe something that works a bit like a portable retirement account across EU countries. You can pay into it, potentially get some tax incentives depending on your home country, and take it with you if you move to another EU member state.

1. The Pan-European Personal Pension Product

Now, here’s where the PEPP tries to help. It sets up a new type of personal pension that any EU citizen can open and keep even if they move from one EU country to another. Think of it as a single pension wrapper that crosses borders.

Each provider can offer an investment plan within the PEPP structure, and in theory, if you decide to leave Spain and move to Germany (or vice versa), you can stay with the same PEPP. This solves the headache many people face when they relocate and have to deal with multiple national pension schemes.

In practice, though, the PEPP is still pretty new. Not many financial institutions have launched an actual PEPP product yet. That means you might see it mentioned, but you might not find it easily at every bank.

Over time, the hope is that insurance companies, banks, and investment platforms across Europe will start saying, “Yes, we offer a PEPP account.” Once that happens, you can go into, say, your bank or log on to an online broker, choose the PEPP, pick your preferred investment style (such as conservative, balanced, or higher risk with stocks), and then deposit money into it as your personal pension.

Europe doesn’t have one single tax policy for all members, so it’s best to ask a tax advisor or read up on your national laws to see what deductions or breaks you can get for contributing to a PEPP.

The hope is that over time, PEPP becomes “the European Roth IRA,” meaning a cross-border pension system that’s super easy to use and beneficial. Right now, we’re not fully there yet.

Also, certain people might prefer other national systems. For instance, the UK has ISAs (tax-free growth accounts), France has PER, Germany has Riester or Rürup, and so on. Those are all local retirement or savings vehicles that can give you benefits similar to what Americans get from their IRAs - though rarely an exact match for the Roth.

2. Other alternatives in European countries

  • UK: Workplace pensions with employer matches + SIPPs (self-invested) and ISAs (tax-free growth).
  • Germany: Riester (government bonus & tax relief) or Rürup (higher limits, no bonus), plus employer “betriebliche Altersvorsorge.”
  • France: PER (Plan d’Épargne Retraite)—tax-deductible contributions, locked until retirement.
  • Spain: Planes de Pensiones with tax relief, but lower contribution limits now.
  • Portugal: PPR (Plano Poupança Reforma) with upfront tax credits and lower tax on gains if held to retirement.
  • Italy: Employer or personal pension funds (with tax-deductible contributions), typically taxed at withdrawal with reduced rates.
  • Netherlands: Strong occupational pensions + “third pillar” lijfrente/banksparen, with tax deductions but annuity payout.

How to benefit from the PEPP

So how do you use the PEPP in practice? If a provider in your country has launched it, you’d simply open an account (similar to opening a bank account or investment portfolio), then pick your chosen strategy (for example, “basic” if you prefer a safe route or “dynamic” if you want stock-based growth), and fund it each month or each year.

If your home country is giving any deduction or credit for PEPP contributions, you’d typically claim that on your tax return. Over time, your investments in the PEPP could grow, hopefully enough to fund part of your retirement. Then, when you eventually retire (or meet certain criteria such as disability, depending on each plan’s rules), you’d have the option to withdraw or convert the account into an annuity, typically with some form of tax being applied. Exactly how that taxation works is up to your national government.

One of the investment platforms that are offering this product is Finax, a robo-advisory/digital wealth management company based in Slovakia:

European Pension by Finax

Conclusion

In summary, you can’t open a real Roth IRA or 401(k) if you’re purely European without U.S. income, but that doesn’t mean you’re out of luck.

We’ve got the PEPP rolling out, plus local solutions that let you get either a tax break now or lower tax later, all intended to help you save for retirement.

It’s not always as straightforward or as famously “tax-free on withdrawal” as a Roth, but with a little research and the right financial advisor, you can still grow a comfortable retirement nest egg in Europe.

Hope we helped!

Autor
Franklin holds a degree in Economics and a Master's in Finance. He has completed Level II of the CFA and has over three years of experience in wealth management, working as a portfolio and investment fund analyst at Golden Wealth Management. He founded the YouTube channel 'Edge Over Hedge' focused on financial literacy. He’s our Portuguese Warren Buffett - just younger.