Germany–Switzerland · Pension taxation

Swiss AHV pensions · German income tax

Swiss AHV pensions: taxation in Germany

Anyone living in Germany who receives a Swiss AHV old-age pension generally needs to include it in their German income tax return. From a German tax perspective, Switzerland’s Old-Age and Survivors’ Insurance (AHV) is comparable to statutory pension insurance. It is therefore generally taxed under section 22 of the German Income Tax Act (EStG). Key factors include the year the pension began, the resulting taxable proportion, the personal tax-free pension allowance and the Germany–Switzerland double taxation agreement.

Basic principle

Swiss AHV pensions are generally taxed in Germany when the recipient lives in Germany

Anyone with a residence or habitual abode in Germany is generally subject to unlimited German income tax liability. This generally also brings foreign pension income within the scope of German taxation.

A Swiss AHV old-age pension is not treated as tax-exempt foreign income. Instead, it must be classified under the German rules for statutory retirement provision.

AHV is the state-run first pillar of Switzerland’s pension system and serves the function of statutory social insurance. German income tax therefore generally follows the system of deferred pension taxation.

More about German residence

The tax treatment of AHV pensions for German residents, including the tax treaty, pension commencement date and distinction from second-pillar benefits, is also explained in our article “Swiss AHV pensions for German residents”.

AHV for German residents (German)

German income tax

Germany generally taxes AHV pensions as part of worldwide income

A person resident in Germany is generally subject to German income tax on both domestic and foreign income.

This also includes pensions from foreign statutory social insurance systems, provided the applicable double taxation agreement leaves Germany with the right to tax.

For Swiss AHV pensions, this is generally the case where the recipient is resident in Germany for treaty purposes.

A pension is not tax-exempt merely because it comes from Switzerland
AHV pensions are included in the German tax return
German pension taxation rules apply
The tax treaty coordinates taxing rights to prevent double taxation
Occupational pension benefits require a separate analysis

Germany–Switzerland tax treaty

Swiss AHV pensions generally fall under Article 21 of the tax treaty

The allocation of taxing rights over a Swiss social insurance pension is not determined solely by German income tax law. The double taxation agreement between Germany and Switzerland must also be considered.

The German Federal Fiscal Court does not treat benefits from Swiss statutory social insurance systems as pensions within the meaning of Articles 18 or 19 of the Germany–Switzerland tax treaty.

Instead, the residual rule in Article 21 generally applies. Under this provision, income not expressly addressed in the preceding articles is generally taxable only in the recipient’s country of residence.

If the recipient is resident in Germany for treaty purposes, the right to tax the AHV pension therefore generally lies with Germany.

Generally no Swiss withholding tax

Where Article 21 of the treaty grants Germany the exclusive right to tax, Switzerland generally has no additional taxing right over the same AHV pension.

German tax classification

Taxation under section 22 EStG

Section 22 EStG governs, among other things, the taxation of life annuities and other benefits from statutory pension insurance.

Comparable foreign pension systems may also fall within this provision. Swiss AHV pensions are generally treated as statutory social insurance pensions.

AHV pensions are therefore not taxed solely on a standardised earnings component. Instead, deferred pension taxation generally applies under section 22 no. 1 sentence 3 letter a double letter aa EStG.

Do not confuse AHV pensions with private life annuities

Private annuities may be taxable only on a statutory earnings component (Ertragsanteil). Swiss AHV pensions, by contrast, generally form part of basic retirement provision and follow the taxable proportion system (Besteuerungsanteil).

Year the pension began

How much of a Swiss AHV pension is taxable in Germany?

The statutory taxable proportion generally depends on the year in which the AHV pension first began.

Since 2023, the taxable proportion has generally increased by 0.5 percentage points for each new annual cohort of pension recipients. For a pension beginning in 2026, for example, it is 84 per cent.

Year the pension began	Taxable proportion	Initial tax-free proportion
2022	82.0%	18.0%
2023	82.5%	17.5%
2024	83.0%	17.0%
2025	83.5%	16.5%
2026	84.0%	16.0%
2027	84.5%	15.5%
2030	86.0%	14.0%
2058	100.0%	0.0%

The taxable proportion is not a tax rate

A taxable proportion of 84 per cent does not mean that 84 per cent income tax is payable. It only determines the starting point for calculating the taxable pension amount. The actual income tax rate depends on total taxable income.

Personal tax-free pension allowance

The tax-free portion is generally fixed as a euro amount

The portion not subject to tax is generally calculated by reference to the pension commencement date and the pension amount.

From the year following the pension’s commencement, this generally becomes a fixed personal tax-free pension allowance. It generally remains a fixed euro amount.

Regular pension adjustments therefore typically increase the taxable portion without a corresponding proportional increase in the original tax-free pension allowance.

Historical figures may need to be reconstructed for older AHV pensions

Anyone who has received an AHV pension for several years before moving to Germany should be able to document the original pension commencement date and, where possible, historical pension amounts. The year of the move does not automatically replace the original year the pension began.

Switzerland → Germany

Receiving an existing AHV pension after moving to Germany

This question frequently arises where a person has already retired in Switzerland and subsequently moves to Germany.

Once German tax liability begins, the Swiss AHV pension generally needs to be taken into account in Germany. However, the original pension commencement date generally remains decisive for the taxable proportion.

Establish the original pension commencement date
Determine German tax liability from the date of the move
Check residence for tax treaty purposes
Document historical AHV pension amounts
Clearly distinguish the Swiss and German tax periods

Review the year of the move separately

If residence changes during the calendar year, it is also necessary to determine when unlimited German tax liability begins and how treaty residence should be assessed during the year of transition.

From 2026

The 13th AHV old-age pension payment is also covered by German pension taxation

Starting in 2026, recipients of a Swiss AHV old-age pension generally receive an additional 13th pension payment once a year in December.

The first payment is made in December 2026. The 13th old-age pension payment generally equals one twelfth of the old-age pensions paid during the relevant calendar year.

For residents of Germany, this additional payment generally also forms part of the Swiss AHV benefits to be taken into account for tax purposes.

2026

First payment

The first 13th AHV old-age pension payment is made in December 2026.

1/12

Calculation

Generally one twelfth of the old-age pensions paid during the calendar year.

German tax

German residents should generally include it in the annual AHV amount relevant for tax purposes.

Old-age pensions only

The 13th AHV payment applies to old-age pensions. Survivors’ and disability pensions generally continue to be paid twelve times a year.

Swiss francs

AHV payments must be converted into euros for German tax purposes

AHV pensions are usually assessed and paid in Swiss francs. The German income tax return, however, requires amounts in euros.

The starting point should generally be the gross AHV benefit. The conversion must be documented consistently and in a way that can be verified.

A consistent conversion method should be used for regular monthly pension payments. Bank charges or different exchange rates applied to the receiving account should not be confused with the gross pension itself.

Do not simply use the net amount credited to the bank account

Exchange rate margins and charges may cause the actual euro amount credited to the bank account to differ from the converted gross Swiss AHV pension relevant for tax purposes.

Example

An AHV pension beginning in 2026

If a Swiss AHV pension begins in 2026, the statutory German taxable proportion is generally 84 per cent.

The remaining proportion generally forms the starting point for calculating the personal tax-free pension allowance.

However, the actual German income tax cannot be determined from this alone. Other income, deductible special expenses, personal allowances and the income tax rates must also be considered.

Step	Treatment
1. Annual AHV pension	Determine the gross pension, including the additional AHV old-age pension payment
2. CHF → EUR	Convert the annual benefit using a documented method
3. Pension commencement	Generally an 84% taxable proportion for a pension beginning in 2026
4. Tax-free pension allowance	Determine the personal tax-free amount under the statutory rules
5. Income tax	Combine the taxable pension amount with other taxable income

AHV, occupational pensions and pillar 3a

Swiss retirement provision must be separated into its individual systems for German tax purposes

Pension provision	Swiss system	Key German tax assessment
AHV	First pillar	Generally statutory pension taxation under section 22 EStG
Occupational pension fund	Second pillar	Examine the mandatory and extra-mandatory components and the fund’s legal form
Vested benefits account	Continuation of second-pillar provision	Distinguish a transfer subject to pension restrictions from a subsequent payment
Pillar 3a	Third pillar	Classify the banking, investment fund or insurance product under German law

A common combination: AHV and a Swiss occupational pension

Many former employees in Switzerland receive both an AHV pension and an occupational pension benefit. These payments must not simply be combined and taxed under the same rule in Germany.

AHV or occupational pension?

Why the distinction matters for tax purposes

Swiss AHV pensions are based on the state social insurance system. Swiss occupational pension funds, by contrast, form part of employment-based retirement provision.

For occupational pension benefits, relevant factors may include the mandatory BVG component, the extra-mandatory component, pension institutions governed by private or public law, older arrangements and lump sum payments.

These distinctions are generally not required for a standard AHV old-age pension.

AHV

State pension

Generally classified consistently in Germany as a statutory social insurance pension.

BVG

Occupational pension

Mandatory and extra-mandatory components may receive different tax treatment.

Private retirement provision

Review the product structure and German insurance or investment income taxation rules.

German tax return

Which documents are needed for a Swiss AHV pension?

Document	Why it is needed
AHV pension award notice	Establish the type of benefit and the original pension commencement date
Annual or monthly statements	Determine the gross AHV pension for the calendar year
Historical pension documents	Reconstruct the tax-free pension allowance for pensions that began in earlier years
Evidence of the move to Germany	Determine when German tax liability began
Evidence of the 13th AHV old-age pension payment	Include the additional payment from 2026
Payment records or bank statements	Substantiate receipt of the payments and currency conversion
Separate occupational pension documents	Keep second-pillar benefits separate from AHV pensions

Practical approach

Assess the tax treatment of a Swiss AHV pension in six steps

Residence

Establish German residence and residence for tax treaty purposes.

Pension commencement

Establish the original year the AHV pension began.

Gross pension

Record the total AHV benefits received during the year.

Euro amount

Convert CHF payments into euros using a documented method.

Section 22 EStG

Determine the taxable proportion and tax-free pension allowance.

Other pension provision

Analyse occupational pensions and pillar 3a separately.

Frequently asked questions

Swiss AHV pensions and taxation in Germany

Is a Swiss AHV pension taxable in Germany?

Yes. If you live in Germany and are resident there for treaty purposes, a Swiss AHV pension is generally taxable in Germany. It is generally treated as a statutory social insurance pension under section 22 EStG.

Where do I have to pay tax on my Swiss AHV pension?

If the pension recipient is resident in Germany under the Germany–Switzerland tax treaty, Germany generally has the right to tax a standard Swiss AHV pension.

Which tax treaty article applies to Swiss AHV pensions?

Under the case law on Swiss social insurance benefits, neither Article 18 nor Article 19 of the treaty generally applies. Taxing rights over the income are generally allocated under the residual rule in Article 21.

Is 100 per cent of a Swiss AHV pension taxable in Germany?

Not for every pension commencement year. The taxable proportion generally depends on the year the pension began. For a pension beginning in 2026, for example, the statutory proportion is 84 per cent.

What is the taxable proportion for a pension beginning in 2026?

For a pension first beginning in 2026, the statutory taxable proportion is generally 84 per cent.

Is the taxable proportion my tax rate?

No. The taxable proportion determines which part of the pension generally needs to be taken into account for tax purposes. The personal tax rate is then determined by reference to total taxable income.

What happens to my tax-free pension allowance?

The tax-free portion is generally fixed as a personal euro amount. Regular subsequent pension increases therefore typically result in a higher taxable pension amount.

I was already receiving an AHV pension before moving to Germany. Which commencement date counts?

The actual original pension commencement date generally remains decisive. The year of a subsequent move to Germany does not automatically replace the original pension commencement year.

Is the 13th AHV pension payment taxable in Germany?

For residents of Germany, the 13th AHV old-age pension payment introduced from 2026 generally also forms part of the AHV benefits relevant for tax purposes.

When is the 13th AHV pension payment made?

The first 13th AHV old-age pension payment is made in December 2026. Thereafter, the additional payment is generally made each December.

Should I enter my AHV pension in Swiss francs in my German tax return?

German income tax is calculated in euros. The gross Swiss pension must therefore be converted from Swiss francs into euros using a documented method.

Is a Swiss occupational pension taxed in the same way as an AHV pension?

No. AHV forms part of the state-run first pillar. For a Swiss occupational pension, the mandatory and extra-mandatory components, the type of pension institution and the form of payment require a separate assessment.

Do I need to claim a credit for Swiss tax on my AHV pension?

Where the treaty grants Germany the exclusive right to tax the relevant AHV benefit, Switzerland generally has no additional taxing right. Any Swiss tax charged should therefore first be reviewed to establish whether it can be refunded.

Related Germany–Switzerland topics

Germany–Switzerland tax advice

Do you live in Germany and receive a Swiss AHV pension?

We review the allocation of taxing rights under the treaty, establish the correct pension commencement date, calculate the taxable proportion and tax-free pension allowance, and coordinate the treatment of your Swiss AHV pension with occupational pensions, vested benefits assets and other Swiss retirement benefits.

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