Short answer: When an American moves abroad with a spouse who is a citizen there, many countries test the citizen spouse’s income (the sponsor, which Norway calls the reference person), not the couple’s. In 2026 the strictest are Norway (NOK 436,957 a year, about $3,774 a month, sponsor only, savings do not count) and the Netherlands (€2,523.96 a month gross, sponsor only, until the sponsor reaches 67), followed by Belgium (€2,456.97 net a month) and Ireland (€75,000 over three years). Austria (€2,064.12 net a month for a couple), the UK (£29,000 a year) and Iceland count both spouses’ income, pensions or savings in some form, and Switzerland, Germany, Finland, Spain and Sweden (long relationships) largely exempt citizens’ spouses. Where the sponsor test bites, a lifetime annuity owned by and paying the sponsor, bought while you still live in the US, turns savings into income in the right name.
Income rules and taxes by country: Norway, Switzerland, Sweden, Italy, Spain, Malta and more, plus how a lifetime annuity fits.
When a couple moves abroad because one spouse was born there, the first surprise is often not the amount. It is whose name the income has to be in. After decades in the US, the savings, retirement accounts and the larger Social Security check usually sit largely in the American spouse’s name, and several countries do not care: they test the citizen spouse. Here is which countries work that way, which do not, and what to do about it.
In a family-reunification or spouse visa, two people are involved. The sponsor is the spouse who is a citizen or resident of the destination country. The applicant is the spouse who needs the permit, here the American. Norway’s UDI calls the sponsor the reference person (referanseperson); the Netherlands calls it the referent; the UK says sponsor or partner.
The question that decides everything is which person’s income the authority tests. There are three patterns:
The rule was written with a different family in mind: a citizen living and working at home who marries someone from abroad. A retired couple coming home after 30 or 40 years in the US is the reverse. The citizen spouse often has little or no income from the home country and may have earned less in the US. The American spouse holds the bigger Social Security, the 401(k) and the brokerage account. On paper the sponsor looks poor even when the couple is comfortable.
Three things make it worse. Savings usually do not count as income in the sponsor countries. The American’s income usually starts to count only after the first permit, once the American works or lives there legally. And some authorities look at prior-year income on their own tax records, which a returning citizen does not have. Get the authority’s answer in writing: phone advice can be contradicted later in writing.
Ranked from the strictest sponsor test to none. USD at USD/NOK 9.6494 (Norges Bank, 2 October 2026), $1.17 per euro, $1.32 per pound and ISK 122.23 per dollar, planning rates. Confirm each figure with the authority the month you apply.
| Country (route) | Sponsor income test? | 2026 amount | Savings accepted? | Annuity fit |
|---|---|---|---|---|
| Norway (spouse of a Norwegian) | Yes, sponsor only | NOK 436,957 a year before tax (3.2 G), about $3,774 a month; pensioner sponsor NOK 243,759, about $2,105 | No (only a discretionary exception) | Strong. Only lifelong income counts; a US annuity is also outside Norway’s wealth tax |
| Netherlands (partner of a Dutch citizen) | Yes, sponsor only; none once the sponsor reaches AOW age (67) | €2,523.96 a month gross with holiday allowance (1 July 2026), about $2,953 | No | Strong while the sponsor is under 67 |
| Belgium (spouse of a Belgian) | Yes, sponsor only | €2,456.97 net a month (110% of the guaranteed minimum wage, from 1 July 2026), about $2,875, plus 10% per extra dependant | Not listed in the law; a shortfall gets a needs review | Good. Pensions count; the applicant’s income does not |
| Ireland (spouse of an Irish citizen) | Yes, one sponsor’s income only | €75,000 gross over the 3 years before applying (for example €25,000 a year), about $2,437 a month | Savings of either spouse may be considered when income falls short | Partial. The test looks back 3 years, so a new annuity may not show yet; ask whether pension income counts |
| Austria (spouse of an Austrian) | Yes, but both spouses’ income in a shared household counts | €2,064.12 net a month for a married couple (2026 reference rate), about $2,415, plus €201.88 per child and rent and loan payments above €386.43 a month | Yes, invested capital or assets | Optional. Useful to keep renewals easy without drawing down capital |
| UK (partner of a British citizen) | Yes, but pensions and savings of both spouses count | £29,000 a year gross, about $3,190 a month | Yes: £88,500 alone, or £16,000 plus 2.5 times the shortfall, held 6 months | Useful when money sits in IRAs or 401(k)s; savings are often cheaper |
| Iceland (spouse of an Icelander) | Yes, but either married spouse can show it | ISK 415,922 a month for a married couple, about $3,403 | Yes, a certified balance covering the permit period | Optional. Savings usually win |
| Sweden (spouse of a Swede) | Exempt for a Swedish citizen in a well-established relationship | Otherwise SEK 13,408 a month left after tax and housing for a couple (from 1 October 2026) | Yes, assets for 2 years | Rarely needed |
| Switzerland (spouse of a Swiss citizen) | No (AIG art. 42) | None; living together is the condition | Not needed | Not needed to qualify; a non-surrenderable annuity is outside cantonal wealth tax |
| Germany (spouse of a German) | Usually not (§ 28 Residence Act) | None as a rule; health insurance required | Not needed | Not needed to qualify |
| Finland (spouse of a Finn) | No, spouses of Finnish citizens are exempt | None | Not needed | Not needed to qualify |
| Denmark (spouse of a Dane) | No income figure; Danish citizens are not exempt from the other conditions | Bank guarantee of DKK 61,709.34 instead | The guarantee is the money test | Not the answer |
| Spain (family of a Spanish citizen) | No means test in the regulation (RD 1155/2024, arts. 94 to 96) | None; 5-year permit with the right to work | Not needed | Not needed to qualify |
| Italy (family of an Italian citizen) | No income requirement in the text (D.Lgs. 30/2007, art. 23) | None in the text; 5-year family permit | Not needed | Not needed to qualify; confirm practice with the Questura |
| Portugal (family of a Portuguese citizen) | No means proof listed for the card (Lei 37/2006, arts. 3(5) and 15) | None listed; ask AIMA whether the resources rule of art. 7 is applied to a returning retiree | Ask AIMA | Likely not needed; the D7 is the fallback |
Links to the Belgium, Ireland, Austria and UK spouse guides go to pages with the full rules; the Spain, Italy and Portugal links go to the retiree-visa pages, which are the fallback if the family route does not fit.
Why I write about this. My mom is Norwegian, my dad is American, and they’re planning the move from the US to Norway. My mom is the sponsor (the host, or “reference person” in UDI’s words), so Norway’s income test falls on her income, not my dad’s. UDI told us in writing that money in an account does not count as income, and only lifelong income does. Their savings were not the problem; the paperwork wanted a monthly number in the host’s name. The rules in other countries are different, but the problem is the same one many retirees hit: the income test, not the net worth. I’m writing this to help others in the same boat as my parents. Read how we worked through the Norway income requirement.
See roughly what a lifetime annuity would cost to close your income gap, then get my personal read by email. I can help while you still live in the US.
Estimates use the September 9, 2026 ImmediateAnnuities.com payout survey (life only) and a 15% cushion. Illustrative, not a quote.
Every figure above is a household figure for the sponsor and the American spouse; none of these routes exists for a single American with no partner there. What changes is who must earn it:
| Rule | Countries | What it means for a US couple |
|---|---|---|
| Sponsor only | Norway, Netherlands, Belgium, Ireland | Income must be in the citizen spouse’s own name and records. The American’s Social Security and savings do not carry the first application |
| Combine (some or all sources) | UK (pensions and savings of both), Iceland (either married spouse), Austria (both spouses’ income in a shared household, assets count) | US money in either name can help; the annuity is optional |
| Exempt or no figure | Switzerland, Germany, Finland, Spain, Italy, Sweden (long relationships), Portugal (confirm), Denmark (guarantee instead) | No income to build; plan for living costs and, where relevant, wealth tax |
Where the sponsor test bites, the practical fix is lifetime income that the sponsor owns and receives: a life-only single premium immediate annuity (SPIA), or a joint and survivor SPIA, with the citizen spouse as owner and annuitant. It turns part of the couple’s savings into income in the right name, and it keeps paying at every renewal.
US gift note (general information, confirm with a tax adviser): moving money from the American spouse to the sponsor to buy the annuity is a gift between spouses. Between two US-citizen spouses, gifts are unlimited. If the sponsor is not a US citizen, there is no unlimited marital deduction; for 2026 the annual exclusion for gifts to a non-citizen spouse is $194,000 (IRS Rev. Proc. 2025-32, IRC 2523(i)). Above that you file Form 709 and use part of your lifetime exemption, and generally no tax is due.
Because the sponsor is the annuitant, these premiums are priced on the sponsor at 62, with no other income, the 2026 bar plus 15% headroom for indexing and exchange rates. Payout at 62 (ImmediateAnnuities.com survey of September 9, 2026, life-only, per $100,000 a month): man $603, woman $582 on average (best quotes $660 and $637). Illustrative, not a quote.
| Country | Bar plus 15%, per month | Male sponsor, 62 | Female sponsor, 62 |
|---|---|---|---|
| Norway (3.2 G) | $4,340 | about $720,000 | about $746,000 |
| Netherlands | $3,396 | about $563,000 | about $584,000 |
| Belgium | $3,306 | about $548,000 | about $568,000 |
| Ireland (€25,000 a year) | $2,803 | about $465,000 | about $482,000 |
Premium equals the monthly gap divided by the payout per $100,000, times $100,000. These are worst cases: the sponsor’s own Social Security (which can start at 62) or a pension shrinks the gap, and every $1,000 a month of the sponsor’s other accepted income cuts roughly $166,000 to $172,000 of premium. A joint and survivor annuity covering both of you pays less per dollar than single life, so get a quote. In Austria, the UK and Iceland, where the American’s income, pensions or savings count, the annuity can be in either name, and savings are often cheaper.
A life-only SPIA or joint and survivor SPIA, or an existing deferred annuity or MYGA converted to lifetime payments. Period-certain annuities, income riders (GLWB) where an account value can still be cashed out, and annuities still accumulating read as savings, not lifetime income, and fail tests that require lifelong income (Norway) or exclude capital (the Netherlands). Where savings are accepted anyway (UK, Iceland, Austria, Sweden), compare the cost honestly before buying.
US side, every country. As a US citizen you stay taxable on worldwide income wherever you live. A US single premium immediate annuity bought with after-tax savings is taxed under IRC 72: an exclusion ratio makes part of each payment a non-taxable return of your premium until the premium is recovered. If you bought it with IRA money, every payment is taxable. The foreign earned income exclusion does not cover annuities (IRC 911(b)(1)(B)(i)). Foreign tax on the payments can be credited on Form 1116, through the treaty’s relief article. Since January 1, 2026, a US citizen with a foreign residence address cannot opt out of federal withholding, even if payments go to a US account (IRC 3405(e)(13), Treas. Reg. 31.3405(e)-1). Withholding is a prepayment, not extra tax. An annuity from a US insurer is not reported on FBAR or Form 8938, and it is not a PFIC.
Treaties. Most US treaties give the country of residence the right to tax an annuity, for example Norway (Article 18(2)), the Netherlands (Article 19(1)), Switzerland (Article 18(2)), Iceland (Article 17(3)) and the UK (Article 17(4)). The saving clause lets the US keep taxing its citizens, and the relief article lets a US citizen credit the foreign tax. If the sponsor is not a US citizen, the sponsor’s own US tax position differs; ask a cross-border preparer.
Net result. The higher of the two taxes usually ends up binding after credits. Country pages give the local rule: Switzerland taxes only a small yield share, Norway taxes the payment as ordinary income, Iceland’s classification of a purchased annuity is not settled.
The trade-offs, stated once: the premium cannot be taken back, payments are level unless you add a cost-of-living rider, they arrive in dollars against a local-currency requirement, and payouts are lower at younger ages. Size the contract to the gap, not to your whole balance, and never assume approval: the authority decides.
Goldstein & Co. LLC dba Goldstein Insurance Services · Hans Goldstein, licensed insurance agent, CA lic. #4273294 · NPN 20602398 · 213-414-2808 · hans@hansgoldstein.com
Education, not tax, legal or immigration advice. Rules, thresholds and exchange rates change; confirm with the consulate or immigration authority and a local tax adviser before you act, and get answers in writing. Hans Goldstein is a licensed insurance agent (CA 4273294) and can only offer annuities to residents of states where he is licensed. Annuity payments are guaranteed by the issuing insurer’s claims-paying ability, not by any government. Payout figures are illustrations from a published survey, not quotes. Immediate annuities are generally irrevocable.