HorizonUK Tax Solutions

UK Tax When Moving from the UK to Germany (2026/27)

When you move from the UK to Germany you usually stop being UK tax resident once you have genuinely left, often with split-year treatment in the year of departure, after which the UK taxes only your UK-source income and certain UK gains while Germany taxes your worldwide income as a resident. The exact outcome depends on the Statutory Residence Test and the UK-Germany treaty.

This guide covers the UK side in detail, which is where a UK Chartered Tax Adviser adds the most value: your residence position, split-year treatment, the 5-year temporary non-residence rule, what stays UK-taxable (rent, property gains and pensions), and a clear pre-departure checklist. The German tax position is given at a high level only and is indicative; confirm the German specifics with a local adviser in Germany.

Written by Jordan Onraet-Wells, Founder & Chartered Tax Adviser (CTA). Last reviewed 26 June 2026.

Key takeaways

  • Your UK tax position after the move turns on the Statutory Residence Test (SRT), not on where you fly to or your visa.
  • Most people leaving the UK part-way through a tax year qualify for split-year treatment, so the year is split into a UK-resident part and a non-resident part.
  • The 5-year temporary non-residence rule can claw back certain gains and income realised while abroad if you return to the UK within five years, but only if you were UK resident in at least four of the seven tax years before you left.
  • UK rental income stays UK-taxable under the Non-Resident Landlord Scheme even after you become non-resident.
  • Gains on UK residential property must be reported and paid to HMRC within 60 days of completion, whether or not you are UK resident.
  • UK pensions are usually taxable, but where (UK or Germany) depends on the UK-Germany double tax treaty.
  • Germany taxes residents on worldwide income; there is a solidarity surcharge and, for members, church tax, and there is no special expat flat-rate (no Beckham-style) regime. Treat all German figures as indicative and confirm locally.
  • Report leaving on the SA109 residence pages of your Self Assessment return for the year you leave (file a P85 only if you will not complete a Self Assessment return); keep evidence of your departure date and day counts.

Do you still pay UK tax after moving to Germany?

Usually yes, but only on UK-source income and certain UK gains once you become non-resident. The key question is whether and when you stop being UK tax resident. While you remain UK resident you are taxed on your worldwide income and gains. Once you become non-resident the UK generally taxes only income arising in the UK (such as UK rent and UK pensions) and gains on UK land and property.

Germany, as your new country of residence, will generally tax your worldwide income. The UK-Germany double tax treaty exists to stop the same income being taxed twice in full, by allocating taxing rights and giving credit relief. The treaty does not remove UK tax on UK-source items automatically; it decides which country taxes what, and at what residual rate.

So the practical answer is that you keep a UK tax footprint for as long as you hold UK-source income or UK assets, even after you have physically and tax-residentially left.

Are you still UK tax resident? The Statutory Residence Test

Your UK residence is decided by the Statutory Residence Test (SRT), a day-counting and connection-factor test set out in HMRC guidance RDR3. It has three parts, applied in order:

  • The automatic overseas tests: if you meet one (for example, fewer than 16 UK days in the year, or full-time work abroad with limited UK days), you are automatically non-resident.
  • The automatic UK tests: if you meet one (for example, 183 or more UK days, or your only home is in the UK), you are automatically UK resident.
  • The sufficient ties test: if neither set of automatic tests is decisive, you compare your UK days against your number of UK ties (family, accommodation, work, 90-day and, for leavers, country ties).

Moving abroad does not, by itself, make you non-resident. If you keep a home, family or significant work in the UK and spend enough days here, you can remain UK resident even while living in Germany. Count your days carefully and keep records. Our Statutory Residence Test guide and the SRT calculator walk through each limb.

Split-year treatment in the year you leave

If you are UK resident for the tax year of your move but genuinely leave part-way through it, split-year treatment can divide that year into a UK part (taxed as resident) and an overseas part (taxed as non-resident). This avoids your German salary and other overseas income being fully taxed in the UK for the months after you leave.

Split-year treatment is not optional or a matter of choice; you either meet one of the statutory cases or you do not. The cases most relevant to someone leaving the UK for Germany include starting full-time work overseas, accompanying a partner who starts full-time work overseas, and ceasing to have a UK home. Each case has precise day-count and timing conditions.

You claim split-year treatment on the SA109 residence pages of your Self Assessment return for the year of departure. See our Split-year treatment guide for the qualifying cases and the split date rules.

The 5-year temporary non-residence rule

The temporary non-residence rule (HMRC reference RFIG21550) is the trap that catches people who leave the UK, realise gains or take certain income while abroad, then come back too soon. It only applies if you were UK resident in at least four of the seven tax years before your year of departure. If that precondition is met and your period of non-residence is five years or less, certain amounts that arose during your time away are taxed in the UK in the year you return, as if they had arisen then.

The rule typically bites on capital gains realised while abroad (for example, selling shares or a second property), and on some income such as certain pension lump sums and close-company distributions. It does not generally re-tax ordinary employment income earned abroad, and gains on assets you both acquired and disposed of while non-resident are usually outside it.

The practical message: if you were UK resident in at least four of the previous seven years, then to keep a gain out of UK charge you generally need to stay non-resident for more than five complete years (broadly five years and a day, measured against your residence pattern). If a return to the UK within five years is possible, plan the timing of any big disposals carefully before you go.

What stays UK-taxable after you leave

Becoming non-resident does not switch off UK tax on everything. Several UK-source items remain within the UK net. The table below summarises the common ones.

Your UK itemStill UK-taxable after you become non-resident?
UK rental incomeYes, under the Non-Resident Landlord Scheme (register with NRL1 to receive rent gross and report via Self Assessment).
UK residential property gainsYes, report and pay within 60 days of completion (Non-Resident Capital Gains Tax).
UK pensionsUsually, but subject to the UK-Germany treaty, which determines whether the UK or Germany taxes the pension.
UK employment for UK workdaysOften, for duties physically performed in the UK after you leave (UK workdays can remain UK-taxable).
Foreign income and gainsNo once non-resident, but watch the 5-year temporary non-residence rule, which can claw back gains realised while away.
What the UK still taxes after you become non-resident (2026/27).

UK rental income and the Non-Resident Landlord Scheme

If you keep a UK property and let it out, the rent stays fully UK-taxable. Under the Non-Resident Landlord Scheme, your letting agent or tenant must in principle deduct basic-rate tax from the rent before paying it to you. To receive the rent gross, you register with HMRC using Form NRL1, after which you account for the tax through Self Assessment.

You still get the personal allowance in many cases (for example, as a UK or EEA national or under treaty terms), and you deduct allowable expenses in the normal way. Mortgage interest, however, is not a normal deduction: relief is given as a basic-rate (20%) tax reducer rather than by deducting the interest from your rental profit. Germany will usually also bring the UK rental income into its worldwide tax calculation, with treaty relief to avoid double tax; confirm the German treatment locally. See our Non-resident landlord tax and Foreign rental income guides.

UK property gains and the 60-day rule

Gains on UK residential property remain UK-taxable even when you are non-resident, under the Non-Resident Capital Gains Tax (NRCGT) rules. You must report the disposal and pay any tax due within 60 days of completion using HMRC's UK property reporting service, separately from your annual return.

Non-residents are generally only charged on the growth in value since April 2015 (for residential property held before then), using a rebasing or alternative computation. Private Residence Relief may still apply for periods the property was your main home, subject to the day-presence conditions that apply to non-residents. Our CGT on UK property for non-residents guide and the CGT property tool set out the mechanics.

UK pensions and the treaty

UK pensions are usually taxable, but the UK-Germany double tax treaty decides where. Treaty articles allocate taxing rights differently for different pension types (state pension, occupational and personal pensions, and government service pensions often follow distinct rules), so the answer is treaty-dependent rather than automatic.

In many cases a UK private or occupational pension paid to a German resident is taxed in Germany, with the UK giving up or limiting its charge under the treaty, but this is not universal and government service pensions are commonly treated differently. Do not assume; check the specific article and consider a treaty claim or an NT (no tax) PAYE code where appropriate. See our Foreign pensions and QROPS guide and HMRC's DT7904 and DT7909 treaty guidance.

Transferring a UK pension abroad: QROPS and the Overseas Transfer Charge

You do not have to move your pension when you move country, and often you should not. If you do consider transferring a UK pension to an overseas scheme, the receiving scheme must be a Qualifying Recognised Overseas Pension Scheme (QROPS) to avoid an unauthorised payment charge.

Even a QROPS transfer can trigger the Overseas Transfer Charge (a 25% charge) unless an exclusion applies, mainly where you are tax-resident in the same country as the receiving scheme. The old exclusion for transfers to EEA or Gibraltar schemes was removed for transfers requested on or after 30 October 2024, so a transfer to a German or other EEA scheme is now generally within the charge unless the same-country exclusion applies. Because pension transfer rules are technical, change over time, and interact with German law, take regulated UK pension advice and confirm the German side locally before moving anything.

The German tax position (indicative, confirm locally)

Once you are tax resident in Germany, Germany generally taxes your worldwide income. The points below are indicative and high level only; German rates, thresholds and reliefs change and depend on your circumstances, so confirm everything with a qualified German adviser.

TopicIndicative German position (confirm with a local adviser)
Basis of taxGerman residents are generally taxed on worldwide income.
Solidarity surcharge (Soli)A surcharge of 5.5% can apply on top of income tax for higher earners.
Church taxMembers of a registered church may pay church tax, broadly in the region of 8% to 9% of income tax, depending on the federal state.
Special expat regimeThere is no Beckham-style or flat-rate expat regime in Germany.
Double taxThe UK-Germany treaty relieves double taxation by allocating taxing rights and giving credit relief.
Indicative German headline only. Not German tax advice; confirm with a local adviser in Germany.

Worked example: split-year and the 5-year trap

This example is illustrative only and uses simple round numbers to show the mechanics, not a real client and not a tax computation you can rely on.

Anna leaves the UK for a full-time job in Munich on 31 July 2026, partway through the 2026/27 UK tax year. She meets a split-year case (starting full-time work overseas), so the year splits at her departure. From 6 April to 31 July 2026 she is taxed in the UK as resident on her worldwide income (say UK salary for those four months). From 1 August 2026 onward she is taxed as non-resident, so her German salary for the remaining eight months is outside UK income tax (Germany taxes it instead, with treaty relief preventing double tax).

Now the 5-year trap. Anna had been UK resident for many years before she left, so she clears the precondition of UK residence in at least four of the previous seven tax years. Suppose she also holds a share portfolio standing at a 100,000 pound gain. If she sells it in, say, 2027 while non-resident and then returns to the UK in 2030 (after only about four years of non-residence), the temporary non-residence rule applies. Because her absence was five years or less, the 100,000 pound gain is treated as arising in the UK in 2030/31, the year she returns, and is taxed then. Had she instead stayed non-resident for more than five complete years before returning, that same gain would have fallen outside the UK charge. The lesson: the timing of the disposal and the length of your absence together decide whether the gain is caught.

Pre-departure UK tax checklist

Getting the paperwork right before and around your move protects your residence position and any refund. Work through the following:

  • Confirm your residence position under the SRT for the year of departure and the first full year abroad; record your departure date and UK day counts.
  • Tell HMRC you are leaving: if you complete a Self Assessment return, report it on the SA109 residence pages and claim split-year treatment there (you do not also file a P85); only if you are not in Self Assessment do you submit Form P85.
  • If you keep a let UK property, register under the Non-Resident Landlord Scheme using Form NRL1 so you can receive rent gross.
  • Plan any large capital disposals around the 5-year temporary non-residence rule before you go, especially if you were UK resident in four of the previous seven years and might return within five years.
  • Review UK pensions and the treaty position; only consider a QROPS transfer after regulated advice and after checking the Overseas Transfer Charge.
  • Diarise the 60-day reporting deadline for any future sale of UK residential property.
  • Keep evidence: flights, German housing and employment contracts, and a day-by-day calendar of UK presence.
  • Engage a German local adviser to confirm German registration, residence and the German tax treatment of your UK income.

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Germany move UK tax checklist

A personalised pre-departure checklist covering your SRT position, split-year claim, P85 and SA109 filing, the Non-Resident Landlord Scheme and the 5-year temporary non-residence rule.

Frequently asked

Uk tax moving to germany: your questions answered

Jordan Onraet-Wells, Founder & Chartered Tax Adviser (CTA)

Written and reviewed by

Jordan Onraet-Wells

Founder & Chartered Tax Adviser (CTA)

Horizon UK Tax Solutions is led by Jordan, a Chartered Tax Adviser (CTA) and accountant with over 10 years of experience, including 7 years at a Big Four professional services firm. Jordan specialises in cross-border taxation, expat tax planning, and helping businesses navigate multi-country compliance.

This is general information about UK tax for 2026/27 as at June 2026, not personal advice, and the Germany-specific points are indicative only and must be confirmed with a local adviser in Germany.

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