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  • UK pensions paid in Germany - double taxation

    I am tax-resident in Germany and receive a UK personal pension (SIPP) which, paid nett of UK tax by the pension provider and also declared in my German tax return. To avoid potentially paying tax twice, I would like to apply for relief under the Double Taxation treaty using form DT-Individual Germany. However, I paid into pension schemes to build up this personal pension for more than 20 years before leaving the UK, presumably receiving tax relief during that time. If I have understood Article 17(3) of the Double Taxation Convention correctly, this pension is taxable only in UK and not in Germany because I got UK tax relief on pension payments for more than 15 years. Is that correct, or should I continue with my application to receive the pension gross (i.e tax-free from UK) and pay tax only in Germany?