Germany–Switzerland
Topic 01Residence & Relocation Between Germany and Switzerland
Moving between Germany and Switzerland can end or establish unlimited German tax liability, while certain German tax obligations may continue. Particular attention is needed where a home remains available in Germany, the tax treaty applies, German income continues after departure, or shareholdings may trigger exit tax consequences.
Overview
What Happens to German Tax Liability When You Move?
Moving to Switzerland does not automatically end all German tax obligations. Conversely, moving from Switzerland to Germany can establish unlimited German tax liability during the year.
From the German perspective, the first question is whether a residence or habitual abode in Germany exists or has been given up. If a home remains available, unlimited German tax liability may continue even where the actual centre of vital interests is in Switzerland.
Where both countries have taxing rights under their domestic laws, the Germany–Switzerland double taxation treaty coordinates treaty residence and taxing rights. Certain German income may also remain subject to German taxation after departure.
This Topic from the Swiss Perspective
TaxRep Switzerland explains arrival, departure and treaty residence with a focus on Swiss tax liability and Swiss tax filings.
Approach
Four Stages of the Tax Assessment
A Germany–Switzerland case should first be assessed under the domestic tax rules of both countries, followed by the tax treaty. The individual categories of income are then considered.
German Tax Liability
Does a residence or habitual abode still exist in Germany, resulting in continuing unlimited German tax liability?
Swiss Tax Liability
When does Swiss tax liability begin on moving to Switzerland, or which Swiss tax obligations end when moving to Germany?
Treaty Residence
Where residence connections exist in both countries, residence for treaty purposes must be determined separately.
Continuing Tax Obligations
German real estate, shareholdings, pensions, employment income and other German income are then assessed individually.
Leaving Germany for Tax Purposes Involves More Than Deregistering with the Local Registration Office.
What matters is whether the connections that establish German tax liability have actually ended. A home that remains available for personal use or certain German income can still have German tax consequences after a move to Switzerland.
Typical Questions
What Needs to Be Clarified When Moving to Switzerland or Germany?
For German taxation, the key factors are residence, the date of the move, and the German income and assets that remain after relocation.
When Does Unlimited German Tax Liability End?
A key consideration is whether the residence and habitual abode in Germany have actually been given up.
Can Keeping a German Home Prevent a Tax Departure?
A home that remains available for personal use may maintain a German residence and therefore unlimited German tax liability.
What If You Have a Residence in Both Countries?
Domestic tax liability and residence for treaty purposes must then be assessed separately.
Which German Income Remains Taxable After Departure?
Depending on the income category, real estate, permanent establishments, certain income from shareholdings or pensions may remain relevant for German taxation.
What Happens in the Year of Departure?
The year of relocation often requires an allocation between periods of unlimited and limited tax liability, as well as coordination with the Swiss tax return.
When Does Exit Tax Apply?
Moving to Switzerland may trigger specific German tax consequences for certain shareholdings in corporations.
When Does German Tax Liability Begin on Arrival?
Establishing a residence or habitual abode in Germany can trigger unlimited tax liability during the year.
What Happens to Swiss Assets After Moving to Germany?
Once unlimited German tax liability begins, Swiss income and financial interests may also become relevant for the German tax return.
Situations
Typical Residence & Relocation Scenarios
The following situations bring together the main German tax questions arising when moving between Germany and Switzerland.
Moving from Germany to Switzerland
End of unlimited German tax liability, possible limited tax liability, exit tax, German real estate and shareholdings.
Explore situationMoving from Switzerland to Germany
Start of German tax liability, Swiss income, occupational pensions, shareholdings and the tax transition year.
Explore situationLiving in Switzerland While Keeping a Home in Germany
A home that remains available, German residence, treaty residence and the distinction between domestic tax liability and treaty allocation.
Explore situationMoving to Switzerland with a German GmbH Shareholding
A shareholding in a German corporation, exit tax, subsequent dividends and a sale after moving to Switzerland.
Explore situationGerman Real Estate After Moving to Switzerland
Continuing German taxation of real estate despite Swiss residence, and the treatment of the income under the tax treaty.
Explore situationMoving to Germany with Swiss Pension Fund Benefits
German tax liability with continuing Swiss pension entitlements, and subsequent lump-sum or pension payments.
Explore situationArticles
Articles on Residence & Relocation
Individual questions about German residence, tax liability after departure and treaty residence are explored in separate articles.
When Does German Tax Liability End on Moving to Switzerland?
Residence, habitual abode and the transition from unlimited to possible limited tax liability.
Read articleKeeping a Home in Germany After Moving to Switzerland
When a home that remains available can maintain German residence and continuing tax obligations.
Read articleTreaty Residence with Homes in Germany and Switzerland
How the double taxation treaty coordinates tax residence where residence connections exist in both countries.
Read articleExit Tax When Moving to Switzerland
When shareholdings in corporations can trigger specific German tax consequences on departure.
Read articleThe German Tax Return in the Year of Moving to Switzerland
Moving during the year, German tax liability before and after departure, and coordination with Switzerland.
Read articleWhich German Income Remains Taxable After Departure?
An overview of common German-source income and continuing German tax obligations for Swiss residents.
Read articleRelated Topics
After Residence, Assess Each Category of Income
Once residence and treaty residence have been determined, individual income categories and assets must be assessed under the relevant German tax rules and treaty provisions.
Employment & Social Security
Cross-border commuters, employment income, working from home and social security.
Explore topicBusinesses & Shareholdings
Companies, shareholdings, management and exit tax.
Explore topicReal Estate
German and Swiss real estate where residence crosses borders.
Explore topicPensions & Retirement Benefits
Swiss pension funds, AHV and German retirement benefits.
Explore topicGermany–Switzerland Tax Advice
Planning to Move to Switzerland or Germany?
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