German taxes for Brits: leaving the UK system, the treaty and your State Pension

Once you live in Berlin, Germany taxes your income from everywhere. Leave the UK system cleanly, and the UK–Germany treaty decides who gets which slice.

The short version

• Germany taxes residents on worldwide income. For 2026 the first EUR 12,348 (about £10,290) is tax-free, and rates climb from 14% to 42%, then 45% at the very top [9].
• The UK taxes by residence, not citizenship: tell HMRC you've gone with form P85, or the SA109 pages if you file Self Assessment [2].
• The 2010 UK–Germany Double Taxation Convention, updated by a 2021 protocol, stops you paying twice [3][4].
• Unlike France or Spain, your UK State Pension is taxable only in the UK under the treaty, though Germany can still count it when setting your rate [4].
• Germany is on DWP's uprating list, so your State Pension still rises every April [5].

How Germany taxes residents

You're fully taxable in Germany (unbeschränkt steuerpflichtig) if you have a home here (Wohnsitz) or your habitual abode (gewöhnlicher Aufenthalt). A continuous stay of more than six months always counts as habitual abode from day one, unless it's purely a holiday or a cure of up to a year. Sign a lease in Friedrichshain and do your Anmeldung, and you're in.

If both countries claim you, the treaty's tie-breaker in Article 4 looks at your permanent home, then your centre of vital interests, then where you usually live, then nationality [4].

German income tax isn't charged in tidy bands like back home. The rate rises smoothly through two "progression zones" before flattening out. These are the 2026 figures from § 32a of the Income Tax Act [9]:

The percentages in the middle rows are the marginal rates the formula produces at each end of the zone. Married couples and registered partners filing jointly have their income split down the middle and the scale applied to each half (Ehegattensplitting), which helps one-earner couples a lot.

Pound conversions use the Bank of England spot rate of 5 November 2026 (£1 = EUR 1.2002).

The extras on top

• Solidarity surcharge (Solidaritätszuschlag). Most people no longer pay it. It only bites once your income tax for the year passes EUR 20,350 (about £16,955), or EUR 40,700 (about £33,910) for a couple filing jointly [10].
• Church tax (Kirchensteuer). 9% of your income tax in Berlin if you're registered as a member of a church that levies it. Our guide to German tax classes, church tax and your Steuer-ID explains how to avoid an unwelcome surprise.
• Social insurance. Employees pay their share of pension, health, care and unemployment insurance through payroll. Together it takes a far bigger bite than UK National Insurance, so compare gross offers carefully.

Savings income is taxed separately at a flat rate (Abgeltungsteuer) of 25% plus surcharges, after a saver's allowance of EUR 1,000 (about £833) a year, or EUR 2,000 (about £1,666) for a married couple, under § 20 of the Income Tax Act.

Your Steuer-ID and the yearly return

Your 11-digit tax ID (Steuer-ID) arrives by post after you register your address, and your employer needs it to put you in the right tax class [1]. Employees have tax taken through the payroll (Lohnsteuer), but many still file a return through ELSTER, the tax office's online portal, and often get money back. The FCDO also warns that you must declare assets held outside Germany when you file, with "severe penalties" if you don't [1].

Leaving the UK tax system properly

HMRC doesn't stop taxing you because you've bought a Deutschlandticket.

1. Check the Statutory Residence Test. It decides if you're still UK resident for the tax year. See the Statutory Residence Test explained.
2. Tell HMRC you're leaving. Use form P85 if you don't normally file a return, or the SA109 residence pages with a paper Self Assessment return, as you can't report leaving online [2].
3. Look at split-year treatment for the year you go, so your German salary isn't caught by UK tax. See split-year treatment.
4. Keep paperwork showing when you moved: your Berlin lease, your Anmeldung certificate, German payslips.

After that, the UK only taxes your UK income, such as rent from a UK flat [2]. As a British citizen you can still claim the UK Personal Allowance on it, with form R43 at the end of each tax year [6].

The UK–Germany treaty: who taxes what

The 2010 convention came into force on 30 December 2010 and has applied since 6 April 2011 for UK income tax and 1 January 2011 for Germany. A protocol signed in London on 12 January 2021 updated it from April 2022 [3].

Three things catch Brits out:

• The 15-year rule. If a UK pension built up for more than 15 years with tax relief in the UK, and the UK actually taxes it, the treaty can hand the taxing right back to the UK [4]. This matters for anyone with a long UK career and a big workplace pension.
• Exempt but not invisible. When Germany exempts UK income, such as rent or a government pension, it can still add it in when working out the rate on your German income (the Progressionsvorbehalt) [4].
• ISAs aren't tax-free here. Germany doesn't recognise the ISA wrapper, so interest and dividends inside it go on your German return. See ISAs when you move abroad.

You still deal with the UK side of any rental, including the Non-Resident Landlord Scheme. Our guide to UK income while you live abroad covers that.

Your UK State Pension in Germany

The good news first: Germany is in the EEA, so your UK State Pension goes up every April exactly as it would back home in Blighty [5]. The full new State Pension is £241.30 a week in 2026/27 [7], and our guide to the UK State Pension abroad explains claiming from abroad.

On tax, this is where Germany differs from most of Europe. Article 17(2) of the treaty says payments under one country's social insurance legislation are taxable only in that country [4]. So a UK State Pension paid to a Berlin resident is taxed by the UK, not the Finanzamt. In practice that often means no tax at all: the full new State Pension comes to about £12,548 a year, just under the £12,570 Personal Allowance for 2026/27 [6][8], which you can claim as a British citizen. Germany can still count it when setting the rate on your other income.

If you've also worked in Germany, Deutsche Rentenversicherung handles any German pension [1]. And if the NHS pays for your German healthcare through an S1, tell the NHS Overseas Healthcare Team if you later move back [1]. See the NHS when you live abroad and the S1.

Never transfer a pension because of a move. A UK workplace or private pension can be paid to you in Berlin as it is. Transfers to overseas schemes need regulated financial advice, can trigger the overseas transfer charge, and attract scammers, so read the FCA and MoneyHelper warnings first. See UK workplace and private pensions abroad.

Getting help

For double taxation questions the FCDO points you to your local Finanzamt or a German tax adviser (Steuerberater) [1]. A tax adviser who knows both countries can check your situation, especially in your first year, when split-year treatment, a German return and a UK return all overlap. For a sanity check from people who've already done their first ELSTER return, try our community group for Brits in Germany.

Sources

1. GOV.UK (FCDO): Living in Germany (last updated 11 December 2025)
2. GOV.UK: Tax if you leave the UK to live abroad
3. GOV.UK (HMRC): Germany tax treaties
4. GOV.UK (HMRC): 2010 UK–Germany Double Taxation Convention as amended by the 2021 Protocol
5. GOV.UK (DWP): Countries where we pay an annual increase in the State Pension (updated 27 October 2026)
6. GOV.UK: Personal Allowance if you live abroad
7. GOV.UK: The new State Pension, what you'll get
8. GOV.UK: Income Tax rates and Personal Allowances
9. Gesetze im Internet: § 32a EStG, income tax scale from 2026
10. Gesetze im Internet: § 3 SolzG, solidarity surcharge threshold

Keep reading

• German tax classes, church tax and your Steuer-ID
• Freelancing in Berlin: tax numbers and the Künstlersozialkasse
• Double taxation agreements and reliefs
• Leaving the UK: telling HMRC, the P85 and your last tax year