Situation
Germany → SwitzerlandMoving from Germany to Switzerland
Moving to Switzerland can end unlimited German tax liability, but many German tax consequences may continue. Particular attention should be paid to actually giving up your German residence, the year of relocation, German-source income, company shareholdings and potential exit taxation.
Overview
When does German tax liability end after moving to Switzerland?
Deregistration with the German registration authority is not the only deciding factor. What matters is whether you continue to maintain a residence or habitual abode in Germany for tax purposes.
Even if unlimited German tax liability actually ends, Germany may continue to tax certain German-source income. This may include income from German real estate, business activities and work performed in Germany, as well as other domestic sources defined by law.
Before moving, you should also assess whether shareholdings in corporations could trigger exit taxation and what tax consequences arise in the year of relocation.
The same situation from the Swiss perspective
TaxRep Switzerland covers the start of Swiss tax liability, reporting assets and income in Switzerland, and the tax treatment that applies after your arrival.
Timeline
Before departure, during the year of relocation and afterwards
Before departure
Review shareholdings, real estate, homes, businesses, remuneration and substantial assets.
Give up your residence
Document when your German home is actually given up and your centre of vital interests moves to Switzerland.
Year of relocation
Clearly distinguish periods of unlimited and, where applicable, limited tax liability, the relevant income periods and treaty residence.
After departure
Continue to address remaining German income, tax returns, advance tax payments and, where applicable, withholding tax procedures.
A home that remains available in Germany may prevent you from ending German tax residence.
If you retain a home and it remains available for your own use, particular care is needed to assess whether your German residence has actually been given up.
Tax Assessment
Six issues to review before moving to Switzerland
1. Residence
Will you give up every home in Germany, or will accommodation remain available for your continuing use?
2. Year of relocation
Which income arises while you are subject to unlimited German tax liability, and which income arises afterwards?
3. Exit taxation
If you hold relevant shareholdings in corporations, it is necessary to assess whether moving abroad triggers taxation of unrealised gains.
4. German real estate
Rental income and certain gains on disposal may remain taxable in Germany after your departure.
5. Businesses & management roles
For German companies, review your shareholding, managing director remuneration and future work performed from Switzerland.
6. Investments & retirement provision
Investments, German pensions and retirement benefits require a fresh cross-border tax assessment after your departure.
Common Questions
Frequently asked questions about leaving Germany
Is deregistration with the registration office enough?
No. Your actual living arrangements are decisive for the tax assessment.
Can I keep my German home?
You can, but a home that remains available may mean that you continue to have a German residence for tax purposes.
What does limited tax liability mean?
Certain German-source income may remain subject to German income tax even if you no longer have a residence in Germany.
What happens to my shareholding in a German GmbH?
In addition to ongoing dividends and any work for the company, potential exit taxation should be assessed before you move.
What happens to my German real estate?
It may continue to create a German tax connection even after you give up your German residence.
How is the year of departure reported?
The German income tax return must reflect the period of unlimited tax liability and, where applicable, German income that remains taxable afterwards.
What applies to bonus payments received after departure?
The allocation may depend on the period of employment and the working days to which the remuneration relates.
What applies to my German pension?
After moving to Switzerland, the allocation of taxing rights over German pension income must be assessed separately under the tax treaty.
Checklist
Documents for assessing the German tax consequences of departure
Residence
Rental or purchase agreement, termination notice or sale documentation, handover record, deregistration and proof of residence in Switzerland.
Tax documents
German tax returns, tax assessments, advance tax payments and ongoing proceedings.
Shareholdings
Ownership percentages, acquisition costs, company agreements and business valuations.
Real estate
Purchase agreements, depreciation records, rental agreements, financing documents and current taxable income calculations.
Employment & businesses
Employment contract, managing director agreement, bonus arrangements and plans for work after departure.
Investments & retirement provision
Securities portfolio statements, details of substantial investments, pension documents and retirement provision records.
In-depth Articles
Technical tax questions when moving to Switzerland
Each article examines a specific tax question within the broader context of leaving Germany.
When does unlimited tax liability end after leaving Germany?
Residence, habitual abode and actually giving up your German home.
Read articleKeeping a home in Germany after moving to Switzerland
Continuing German residence, dual residence and residence under the tax treaty.
Read articleExit taxation when moving to Switzerland
Shareholdings in corporations, unrealised gains and the tax consequences of moving abroad.
Read articleThe tax return for the year of moving from Germany to Switzerland
Relevant periods, allocation of income, changes in residence and continuing German tax liability.
Read articleGerman tax liability after moving to Switzerland
Which German-source income may remain taxable in Germany after you give up your residence.
Read articleRelated Topics
Further topics relevant to leaving Germany
Residence & Relocation
Residence, treaty residence, moving to Germany and leaving Germany.
Explore topicBusinesses & Shareholdings
Exit taxation, company shareholdings and management roles.
Explore topicReal Estate
German real estate after giving up your German residence.
Explore topicRetirement Provision & Pensions
German pensions, Swiss residence and the allocation of taxing rights under the treaty.
Explore topicTax Returns & Reporting Obligations
The year of departure and subsequent German filing obligations.
Explore topicGermany → Switzerland Tax Advice
Are you planning to move your tax residence to Switzerland?
Before your move, we assess the termination of your German residence, the year of departure, remaining German-source income, company shareholdings, real estate and potential exit taxation.
Request a Tax Review of Your Move