Tax and pension in Germany: the € 15,000 threshold that turns everything around

If you are going to work in Germany, the tax treaty with Germany is straightforward: wages are taxed where you work, so you pay German wage tax.

The surprise of this treaty lies with pensions. It is big enough to adjust your departure planning around.

What is the € 15,000 threshold?

The main rule is the same as everywhere: pensions, annuities and AOW (the Dutch state pension) are taxed in the country where you live. For you that will soon be Germany.

But article 17 of the treaty has a second paragraph that no other Vertrekklaar corridor knows. If the total gross amount of your Dutch pensions and annuities in a calendar year comes above € 15,000, the Netherlands may tax it too, as the source state: the country the income comes from. For that the Belastingdienst adds up:

• your statutory pension (AOW and Anw, the survivor's benefit)
• your occupational pension
• your annuity payments

A UWV benefit (WW, WAO, WIA, Wajong) does not count in that sum. It is always taxed in the Netherlands, however small.

For most retired emigrants the total lies well above that. An AOW couple alone is over it. The consequence: the Netherlands taxes that income, while Germany as country of residence has your worldwide income in view. Double taxation is settled via the treaty.

Work it through once before departure, especially if you can choose when an annuity starts. In the year of emigration the Belastingdienst tests the threshold on the pension of the whole calendar year, not only on the months after your move. The treaty speaks of "the total gross amount thereof in any calendar year".

If you ever worked for the government, a separate rule applies as well. A government pension (such as ABP from a public-service employment) stays taxed in the Netherlands as long as you do not hold German nationality. A lump-sum commutation of a pension or annuity from the Netherlands is also taxed in the Netherlands.

Where do you pay tax on your wages?

For wages the state-of-employment principle applies: work in Germany is taxed in Germany.

If you keep working from home in Germany for your Dutch employer, since 2026 the number of days counts. A home-working day is a day with more than 30 minutes of work at home.

• With more than 34 home-working days a year you pay tax in Germany on the wages for all those days.
• With at most 34 that stays the Netherlands.

If you keep Dutch income alongside (for instance a rented-out house or a part-time job at a distance), know the 90% rule. Whoever, as a resident of an EU country, sees at least 90% of their income taxed in the Netherlands counts as a qualifying non-resident taxpayer. They keep the right to the same deductions and tax credits as a resident. Partners can even qualify together. For most emigrants with a German job this does not apply; the Dutch deductions then lapse.

For the year of your move you file the M return, the tax return for the year of emigration, online. Before departure, adjust your provisional assessment if money flows through it monthly.

In Germany you file the Einkommensteuererklärung, the German tax return, for your first year. In that year it is often compulsory. That is the case with Steuerklasse III/V or the Faktorverfahren. It is also the case if, besides your German wages, you had more than € 410 of income that Germany does not tax, such as your Dutch income from the months before the move. If you file a compulsory return yourself, it must be in by 31 July of the year after.