Situation
Switzerland → GermanyMoving from Switzerland to Germany
Moving to Germany generally marks the start of unlimited German income tax liability. At the same time, Swiss employment income, securities portfolios, real estate, AHV, occupational pension funds, vested benefits, Pillar 3a and company shareholdings may continue to raise cross-border tax questions. The first step is therefore to establish the date on which German tax residence begins. Each type of income and asset is then assessed under the relevant specialist tax rules.
Overview
What changes for tax purposes when you move to Germany?
Once you establish a residence or habitual abode in Germany, foreign income generally also comes within the scope of German taxation.
The first step is therefore to determine the date on which German tax liability begins and whether you continue to have tax residence or a home in Switzerland at the same time.
Your existing Swiss circumstances must then be assessed in the relevant areas: employment and social security, investments and withholding taxes, real estate, retirement provision and pensions, businesses and shareholdings, and tax returns and reporting obligations.
The same situation from the Swiss perspective
TaxRep Switzerland covers the end of Swiss tax liability, the cantonal tax period in the year of departure, and continuing Swiss tax and withholding tax obligations after your move.
Timeline
Before arrival, when changing residence and afterwards
Before arrival
Secure Swiss tax documents and historical records for securities portfolios, real estate, retirement provision and shareholdings.
Date of arrival
Document the start of your German residence and the actual change in your living arrangements.
Year of arrival
Determine treaty residence and allocate income to the periods before and after the change of residence.
After arrival
Apply the relevant German domestic and tax treaty rules to Swiss income and assets.
Secure historical records before moving
Particularly important documents include purchase records and acquisition costs for securities and shareholdings, contribution histories and contracts for occupational pension funds, vested benefits and Pillar 3a, and purchase and financing documents for Swiss real estate.
Tax Assessment
Six tax areas may be affected by your move
1. Residence & year of arrival
When does German tax liability begin, when does treaty residence change, and how is the year of relocation treated?
2. Employment & social security
If you continue working for a Swiss employer, the place of work, cross-border commuter status, working from home, withholding tax and social security must be assessed separately.
3. Investments & withholding taxes
Swiss securities portfolios, dividends, interest, funds, gains on disposals and Swiss withholding tax are subject to specific German and treaty rules.
4. Real estate
Swiss real estate remains relevant for Swiss tax purposes. Its income and any subsequent sale must also be assessed from the German perspective.
5. Retirement provision & pensions
Swiss old-age and survivors’ insurance (AHV), occupational pension funds, vested benefits and Pillar 3a each follow their own income tax and treaty rules.
6. Businesses & shareholdings
Shareholdings, dividends, managing director or board roles, and the place of effective management require separate assessment.
Coordinate the tax issues arising from your move
Moving to Germany can affect several aspects of your tax position at once. The specialist guides explain the treatment of each type of income and asset and help you identify the issues to address.
- Determine the arrival date under Residence & Relocation
- Review work arrangements under Employment & Social Security
- Assess securities portfolios under Investments
- Review property under Real Estate
- Assess AHV and pension benefits under Retirement Provision & Pensions
- Review shareholdings under Businesses & Shareholdings
Common Questions
Questions frequently raised when moving from Switzerland
When do I become subject to German tax?
Residence and habitual abode are decisive. The registration date is important evidence, but it is not automatically the date on which German tax residence begins.
How is the year of arrival treated?
The start of German tax liability, treaty residence and Swiss income before and after the change of residence must be allocated to the relevant periods.
Can I continue working for my Swiss employer?
Yes. However, the cross-border commuter rules, actual working days, working from home and applicable social security legislation must be assessed for tax and social security purposes.
Can I keep my Swiss securities portfolio?
Generally, yes. Once German tax liability begins, investment income and disposals must be treated under German tax law.
What happens to Swiss withholding tax?
The Swiss tax deduction, the residual tax permitted under the treaty, refunds and German foreign tax credits must be distinguished from one another.
What happens to my Swiss real estate?
Switzerland retains significant taxing rights over Swiss real estate. Germany treats the income under German law and the tax treaty.
What applies to AHV and occupational pension funds?
Current pensions, future pension benefits and lump-sum payouts must be classified separately according to the type of pension arrangement.
What applies to vested benefits and Pillar 3a?
The balances should be fully documented when you move to Germany. Their subsequent tax treatment depends on the product and the form of payout.
What happens to my Swiss AG or GmbH?
Your shareholding and the company continue to exist. However, distributions, management roles and, in particular, any management of the company from Germany must be assessed.
Must I report all my Swiss assets in Germany?
Holding an asset does not necessarily create a German tax charge. However, income, disposals and certain other circumstances may need to be reported.
Checklist
Documents for assessing the German tax consequences of your arrival
Residence
German rental or purchase agreement, key handover, registration, Swiss deregistration and the actual moving date.
Employment
Employment contract, work locations, arrangements for working from home, salary certificates, withholding tax and social security records.
Portfolios & bank accounts
Portfolio holdings, acquisition costs, purchase records, annual statements, tax statements and income statements.
Real estate
Purchase documents, mortgages, rental income and expense statements, tax valuations and Swiss property tax documents.
AHV & occupational pension funds
AHV documents, pension fund statements, contribution histories and records of benefits already received.
Vested benefits & Pillar 3a
Vested benefits accounts or insurance policies, Pillar 3a contracts, contributions and previous transfers.
Shareholdings
Company agreements, ownership percentages, acquisition costs and business valuations.
Swiss taxes
Recent tax returns and assessments, together with evidence of Swiss tax withheld on income and investment returns.
Further Reading
Two key questions when moving to Germany
Establish when German tax liability begins using the Residence & Relocation guidance. The Tax Returns & Reporting Obligations topic explains how to report the year of relocation.
The start of German tax liability when moving from Switzerland
Residence, habitual abode, the actual move-in date, a home retained in Switzerland and treaty residence.
Read articleThe tax return for the year of moving from Switzerland to Germany
The start of German tax liability, allocation of income between periods, tax rate effects and reporting the year of relocation.
Explore Tax ReturnsSpecialist Topics
Detailed guidance for your Swiss income and assets
Once the arrival date has been established, the following Germany–Switzerland topics guide the assessment of your individual circumstances.
Employment & Social Security
Swiss employers, cross-border commuters, working from home, working days, business travel, secondments, work in multiple countries and A1 certificates.
Explore topicInvestments & Withholding Taxes
Swiss securities portfolios, shares, dividends, interest, funds, gains on disposals and Swiss withholding tax.
Explore topicReal Estate
Swiss real estate while resident in Germany, rental income, sales, financing and treaty treatment.
Explore topicRetirement Provision & Pensions
AHV, occupational pension funds, vested benefits, Pillar 3a, pension payments and lump-sum benefits.
Explore topicBusinesses & Shareholdings
Swiss AGs and GmbHs, dividends, disposals of shareholdings, management roles and the place of effective management.
Explore topicTax Returns & Reporting Obligations
The year of arrival, Swiss income, withholding taxes, investments, real estate and cross-border reporting.
Explore topicBroader Context
Residence and relocation between Germany and Switzerland
Residence & Relocation
This topic covers residence, habitual abode, treaty residence, moving to and leaving either country, and continuing tax obligations between Germany and Switzerland.
Switzerland → Germany Tax Advice
Are you moving from Switzerland to Germany?
We assess the start of German tax liability, treaty residence and the year of arrival, then coordinate the relevant issues involving employment, investments, real estate, retirement provision, shareholdings and tax returns.
Request a Tax Review of Your Move