schweizer-einkuenfte-deutsche-steuererklaerung

Tax return

Germany · Swiss income · Tax treaty · Reporting

Swiss income in your German tax return

If you are tax resident in Germany and receive income from Switzerland, you must first classify it under German tax law. The Germany–Switzerland double taxation agreement then determines whether Germany taxes the income, grants a credit for Swiss tax, or exempts the income and, where applicable, takes it into account when determining your tax rate under the progression proviso. Figures from a Swiss salary certificate, tax statement or assessment therefore cannot simply be copied into your German tax return.

General principle

Foreign income is classified separately for German tax purposes

If you are subject to unlimited German income tax liability, income from Switzerland generally also falls within the scope of the German tax assessment.

This does not mean that every amount received from Switzerland is taxed again in Germany. The Germany–Switzerland double taxation agreement allocates taxing rights between the two countries and, together with German domestic law, determines how double taxation is avoided.

The correct order is therefore: German tax classification → treaty allocation → German reporting.

Reporting framework

Four questions before making an entry

The German tax return reflects the outcome of the tax analysis. Depending on the circumstances, the same type of Swiss payment may be fully taxable, eligible for a foreign tax credit, exempt or relevant only to the applicable tax rate.

  • What category of income applies under German law?
  • Which country may tax the income under the treaty?
  • How does Germany provide relief from double taxation?
  • Which German tax return schedule is used to report the amount?

Treaty relief method

Distinguish taxation, tax credits and exemption

DE

Germany taxes the income

Germany has the taxing right or may tax the income as the country of residence. The income is calculated under German law.

Credit

Foreign tax credit

If Switzerland may also tax the income, the Swiss tax ultimately retained may be credited under the applicable German rules.

Exempt

Exemption

If the treaty assigns taxing rights to Switzerland and Germany provides an exemption, the income may nevertheless affect the German tax rate under the progression proviso.

Tax paid in Switzerland does not determine the German treatment

Whether Swiss tax was correctly levied, can be reclaimed or qualifies for a German tax credit must be assessed separately. The fact that Swiss tax was withheld does not replace an assessment under the treaty.

German tax return schedules

Which schedule may be relevant for Swiss income?

The required schedule depends on the category of income. Anlage AUS is not a universal substitute for all schedules relating to foreign income.

Situation Typical German schedule Purpose
Swiss employment income Anlage N / Anlage N-AUS Employment income, work abroad, treaty exemption and workdays.
Frontier workers Anlage N / N-Gre where applicable Information relating to frontier-worker status and the treatment of employment income.
Dividends and interest Anlage KAP Investment income not subject to German withholding tax and foreign tax eligible for a credit.
Foreign investment funds Anlage KAP-INV Investment fund income that was not subject to German withholding tax.
Swiss real estate Anlage V / Anlage AUS where applicable Calculation of income under German rules, treaty treatment and effects on the tax rate.
AHV / foreign pensions Anlage R-AUS / Anlage AUS where applicable Foreign pension benefits and treaty exemption where applicable.
Swiss occupational pension benefits Depending on the German classification, particularly Anlage R-AUS The specific schedule depends on the classification of the benefit under German law.
Professional / commercial business income Anlage S or G / Anlage AUS where applicable Category of income and international tax treatment.
Foreign tax / treaty exemption Anlage AUS, where applicable Foreign tax credits, exempt foreign income and the progression proviso.

Investment income is an important special case

Where the German flat-rate investment income tax regime applies, foreign investment income is generally not simply reported through Anlage AUS. The relevant information is provided primarily in Anlage KAP or, for foreign investment funds, in Anlage KAP-INV.

Employment income

First classify Swiss employment income under Articles 15 and 15a of the tax treaty

The employer’s location alone does not determine the treatment of employment income. Relevant factors include the actual places of work, any applicable frontier-worker rule, days worked from home and any other special treaty provisions.

Only after this substantive allocation has been completed can it be determined which employment income is taxable in Germany, exempt or relevant to the German tax rate.

N

Employment income

The German reporting is based on the employment income determined under German law and the treaty.

N-AUS

Work performed abroad

Employment exercised abroad may require additional information in Anlage N-AUS.

Treaty

Exemption

Employment income exempt under the treaty may be subject to Germany’s progression proviso.

Further guidance on workdays and employment income

Frontier-worker status, working from home, actual workdays and the allocation of employment income are covered in more detail under Employment & Social Security . This page explains the subsequent reporting.

Investment income

Swiss securities account figures must be prepared for the German tax return

German investment income tax is generally not withheld on income from a Swiss securities account. Dividends, interest and gains or losses on disposals must therefore be determined for German purposes using the Swiss bank documents.

Investment funds are also subject to the German Investment Tax Act. A Swiss bank statement is therefore not automatically equivalent to a German tax certificate.

KAP

Dividends & interest

Gross income and, where applicable, foreign tax eligible for a credit are determined under German law.

KAP-INV

Investment funds

For funds held with a foreign custodian, distributions, advance lump-sum investment income amounts (Vorabpauschalen) and gains or losses on disposals may be relevant.

CHF→EUR

Currency conversion

Amounts in Swiss francs must be appropriately converted into euros for the German tax calculation.

Further guidance on the taxation of securities accounts

Acquisition costs, fund taxation, disposal gains, dividends and Swiss withholding tax are covered in more detail under Investments & Withholding Taxes .

Real estate

Swiss rental income is calculated separately for German tax purposes

A Swiss tax assessment can provide important underlying information, but it does not replace the German calculation of income. For German purposes, rental receipts, deductible expenses and depreciation are determined under German tax law.

The next step is to assess how the Germany–Switzerland tax treaty affects German taxation and whether the income remains relevant under the progression proviso.

A Swiss tax value is not automatically the German tax value

Swiss cantonal values, imputed rental values and tax depreciation cannot be used for German income tax purposes without being reviewed.

Real estate taxation is covered separately

Swiss taxing rights, rental income and property sales are covered under Real Estate .

Retirement provision & pensions

AHV and Swiss retirement benefits are classified under German law

For Swiss pensions and retirement benefits, the Swiss name of the product is not sufficient. Before preparing the German tax return, it is necessary to determine which German retirement provision or pension category the particular benefit is comparable to.

Anlage R-AUS may be particularly relevant for foreign pensions and other benefits from foreign insurance policies, pension contracts and occupational pension institutions.

AHV

AHV

Swiss statutory old-age benefits must be classified under German law and the treaty before they are reported.

Pension

Occupational pension fund

Pension payments and lump-sum benefits from occupational pension schemes require a separate classification under German law.

R-AUS

Reporting

The appropriate schedule depends on the German classification of the specific foreign benefit.

Further guidance on classifying retirement benefits

AHV, occupational pension funds, vested benefits and Pillar 3a are covered under Retirement Provision & Pensions .

Businesses & shareholdings

Swiss shareholdings can give rise to several categories of income at the same time

A shareholding in a Swiss AG or GmbH can give rise to several different items in the German tax return: dividends, remuneration as a managing director or board member, disposal gains and, where applicable, matters falling within German international tax rules.

These items must not be combined merely because they originate economically from the same Swiss company.

Div

Dividends

Income from shareholdings has its own treatment under German law and the treaty.

Pay

Remuneration

Managing director or board remuneration must be classified separately.

Sale

Disposals

A share sale follows its own rules and may fall within section 17 of the German Income Tax Act (EStG).

AStG

International tax rules

Depending on the structure, additional disclosures may be required under German international tax rules.

Assess the corporate structure separately

The place of management, shareholdings, dividends and the German Foreign Tax Act (AStG) are covered in more detail under Businesses & Shareholdings .

Swiss tax

Swiss tax withheld does not automatically qualify for a full German tax credit

Before claiming a German foreign tax credit, it is necessary to establish whether Switzerland may ultimately retain the tax under the treaty or whether there is an entitlement to a refund or reduction.

Only the foreign tax burden remaining under the applicable rules can be taken into account within Germany’s foreign tax credit provisions.

01

Swiss tax deduction

Identify the Swiss withholding tax actually deducted from earnings or investment income.

02

Check the treaty

Determine the amount of tax Switzerland may ultimately retain.

03

Germany

Report the remaining tax in the appropriate German tax return schedule.

Anlage AUS is not the correct schedule for every foreign tax

Investment income, in particular, has its own reporting rules. Foreign tax must therefore be entered according to the category of income and the relevant German schedule.

Progression proviso

Tax exemption does not always mean there is no effect on German tax

Certain foreign income exempt from German tax under a double taxation agreement may still be taken into account when determining the tax rate applicable to other taxable income.

For this purpose, the foreign income generally has to be calculated under German tax rules. A Swiss taxable profit or net salary is therefore not automatically the amount to be used for the German progression proviso.

Dedicated specialist article

The calculation and the different situations in which it applies are explained in more detail in the progression proviso for Swiss income (in German) .

Supporting documents

Swiss documents typically required

Pay

Employment income

Salary certificate, withholding tax statements, employment contract and workday calendar.

Bank

Investments

Annual statements, securities tax statements, income statements and purchase records.

Property

Real estate

Rental statements, purchase documents, financing and ongoing expenses.

Pension

Retirement provision

AHV records, occupational pension fund certificates, benefit statements and contractual documents.

AG

Shareholdings

Ownership percentage, acquisition costs, dividend and remuneration documents.

Tax

Swiss tax

Tax assessments, withholding tax records, Swiss investment withholding tax and refunds.

FX

Currency

Document CHF amounts, payment dates and the exchange rates used.

Treaty

Residence

For moves to or from Germany, residence dates and, where applicable, further evidence of tax residence.

Order of assessment

Reporting Swiss income in eight steps

01

Residence

Determine the period of German tax liability and residence for treaty purposes.

02

Income category

Classify the Swiss payment under German tax law.

03

Amount

Calculate the income under German tax computation rules.

04

Tax treaty

Determine the taxing rights and the method of relief.

05

Swiss tax

Review the Swiss tax and any potential refund.

06

Schedule

Select the correct German income tax return schedule.

07

Tax rate effect

Assess the effect of exempt Swiss income.

08

Evidence

Keep clear records of Swiss documents and calculations.

Common mistakes

Where Swiss income is frequently treated incorrectly in German tax returns

01

Copying Swiss figures

Swiss taxable income figures are used without recalculating them under German rules.

02

Overlooking the treaty

Income is reported without first determining the international allocation of taxing rights.

03

Using the wrong schedule

All foreign income is reported indiscriminately through Anlage AUS.

04

Reporting net instead of gross

Swiss tax deductions are subtracted directly from the income reported for tax purposes.

05

Ignoring refunds

Refundable Swiss tax is treated as a final foreign tax burden.

06

Overlooking the tax rate effect

Income exempt under the treaty is removed entirely from the German tax calculation.

07

Using CHF amounts without review

Amounts are entered without an appropriate conversion into euros.

08

Missing documentation

Workdays, acquisition costs or Swiss tax payments cannot be substantiated later.

Frequently asked questions

Swiss income in your German tax return

Do I have to report Swiss income in Germany?
If you are subject to unlimited German tax liability, Swiss income generally has to be included in the German tax assessment. Whether Germany actually taxes it is then determined under German law and the treaty.
Can I simply copy the figures from my Swiss tax return?
No. For German purposes, income generally has to be calculated and classified under German tax rules. Swiss tax figures may differ.
Does every type of Swiss income go in Anlage AUS?
No. The category of income first determines the relevant German schedule. Employment income, investment income, real estate and pensions each have their own reporting framework. Anlage AUS is used additionally in the circumstances for which it is intended.
Where do I report Swiss employment income?
Foreign employment income is generally reported through the employee schedules. Anlage N-AUS may be particularly relevant where work is performed abroad. The taxing rights under the treaty must be established first.
Where do I report dividends from a Swiss securities account?
Private investment income not subject to German withholding tax is generally reported in Anlage KAP. Anlage KAP-INV may also be relevant for investment funds held with a foreign custodian.
Can Swiss withholding tax be credited in full?
Not automatically. The first step is to establish which portion Switzerland may retain under the treaty and which portion can be reclaimed.
How is Swiss real estate treated?
The income is first calculated under German law. The treaty is then used to determine the applicable taxing rights and the effect of the income in Germany.
Where do I report a Swiss AHV pension?
Anlage R-AUS may be particularly relevant for foreign pensions. However, the specific benefit must first be classified under German law and the treaty.
What does the progression proviso mean?
Certain foreign income that is exempt from German tax may still be taken into account when determining the tax rate applicable to other taxable income.
What applies in the year I move to Germany from Switzerland?
In particular, it is necessary to determine when unlimited German tax liability begins and which Swiss income belongs to the period before or after the move.
What applies in the year I move to Switzerland?
In addition to establishing when unlimited German tax liability ends, income must be allocated to the relevant periods. Any continuing German tax obligations and effects on the tax rate must also be considered.
Which documents should I retain?
In particular, Swiss salary certificates, tax assessments, withholding tax records, bank and securities account documents, property statements, pension and occupational pension fund documents, and evidence of acquisition costs and payment dates.

Germany–Switzerland tax advice

Do you need to report Swiss income in Germany?

We coordinate the underlying tax analysis with your German tax return: allocation under the treaty, calculation of income under German rules, foreign tax credits, the progression proviso, the correct schedules and Swiss supporting documents.

Request a tax return review