UK Pensions on a German Tax Return (2025)
UK pensions on a German tax return? The treaty allocates taxing rights by pension type. See how Germany applies progression and when to claim UK relief.
How should I report my UK pensions on my German income tax return for 2025?
If you are tax resident in Germany, the UK State Pension is generally taxable in the UK under the treaty, while a UK private pension is generally taxable in Germany. UK government-service pensions have a separate rule, and UK pensions exempt in Germany can affect your German tax rate. The result depends on your residence, nationality, pension type and contribution history.
This guide covers the German 2025 income tax return. The figures below are illustrative.
Which country can tax each UK pension?
UK State Pension. Article 17(2) of the UK–Germany tax treaty generally allocates the right to tax UK social security pensions to the UK. Keep UK tax records so you can substantiate the treaty treatment in Germany.
UK government-service pension. Article 18(2) generally allocates UK public-service pensions to the UK. The taxing right generally shifts to Germany if the recipient is both resident in Germany and a German national. Check whether the pension qualifies as a government-service pension.
UK private or occupational pension. Article 17(1) generally allocates taxation to Germany for a German resident. Under Article 17(3), the UK may retain the taxing right if the pension is attributable to contributions that received qualifying UK tax relief for more than 15 years. The exception is subject to additional conditions, including effective UK taxation and whether relief was clawed back or the duration condition was also met in Germany.
For certain pensions already in payment before 30 December 2010, HMRC also describes an election under the earlier treaty if the pension is subject to tax in Germany. The election excludes UK public-fund pensions.
How does German tax progression work?
Germany can take treaty-exempt pensions into account when setting the tax rate on income taxable in Germany. This is the Progressionsvorbehalt under section 32b EStG. Germany determines the relevant pension amount under German tax rules, so it can differ from the gross amount on a UK statement.
Suppose you have €8,000 of taxable German income and €16,000 of exempt pension income after applying German rules. Germany uses the combined €24,000 to determine the applicable rate, then applies that rate to the €8,000. Progression can therefore produce German tax even when your taxable German income alone is below the basic allowance.
How do I prepare or correct the return?
Gather a statement for each pension, its start date, any contribution history relevant to treaty relief and evidence of UK taxation. Review Anlage R-AUS for foreign pension income and Anlage AUS for foreign income subject to progression, checking which entries apply to each pension.
If you receive a reminder from the Finanzamt, check the date stated in the letter and whether the original filing deadline has already passed. If you discover an omission in a past return that may have understated German tax, check promptly whether a correction is required under section 153 AO. Which years can still be corrected depends on the filing history and the applicable limitation rules.
FAQ
Should I report a UK pension if Germany exempts it under the treaty?
Yes, where the pension is subject to German tax progression. The exempt amount can affect the tax rate on other income taxable in Germany.
Does a UK tax deduction tell me which country can tax a pension?
A deduction shows what the payer withheld. The treaty treatment depends on the type of pension, your tax residence and any applicable exception.
How can I claim back UK tax withheld on a private pension taxable only in Germany?
Use HMRC’s DT-Individual (Germany) form to request relief at source for future payments or repayment of UK tax already withheld, subject to eligibility and time limits.
What should I ask a private pension provider for?
Ask for the pension start date, the scheme type and any records of the contribution period and UK tax relief. These details help establish whether the treaty’s more-than-15-years rule applies.
Sources
This article sets out a general framework and does not constitute personalised tax advice. Tax rules can change from year to year, and treatment depends on your exact circumstances.
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