Tax return after working in France and Germany

57 posts in this topic

Posted

Hi All,

I have worked 3 months in France and rest of the time in Germany in 2011. I have paid taxes in France for those 3 months ( totally seprate job than German) and then i shifted here in Germany and got new job.

Can someone please guide me how can i claim tax returns for both? Germany and France.... if i only claim tax returns from Germany, am i supposed to mention my income from France as well?

Thanks for reply!

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Posted

Can someone please guide me how can i claim tax returns for both? Germany and France....

Employ a French tax advisor for the French one?

For the German one you can either:

  • do it yourself using the step-by-step instructions in the TT Elster wiki (yellow section for employees),
  • or - if you only had employee income - pay a Lohnsteuerhilfeverein to do it for you, see Claiming tax deductions for details and cost.

It would probably be best to let a Lohnsteuerhilfeverein do it for you for 2011, since you have lots of potential deductions you can claim for, like moving costs from France to Munich and maybe "doppelte Haushaltsführung" (see post no. 220 in Filing a Tax Return) and they would fill in the forms for you so that you claim as much as possible.

if i only claim tax returns from Germany, am i supposed to mention my income from France as well?

Yes, in the tax form Anlage N-AUS if you were an employee in France.

If you were not an employee, fill in your French income into Anlage AUS.

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Posted

Hi Panda,

Thanks for helping again the community. One quick question, Zu versteuerndes Einkommen: your German income in euro: Here income means before tax or after deducting tax, the money you get?

Thanks,

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Posted

One quick question, Zu versteuerndes Einkommen: your German income in euro: Here income means before tax or after deducting tax, the money you get?

It's the taxable income, also known as the the gross income, i.e. it's before tax.

The amount you get paid out would be the net income, which you get after you deduct from your gross income the income tax that you calculated with that nifty online income tax calculator.

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Posted

I have worked 3 months in France and rest of the time in Germany in 2011. I have paid taxes in France for those 3 months ( totally seprate job than German) and then i shifted here in Germany and got new job.

Can someone please guide me how can i claim tax returns for ... France

Instructions for the French tax return forms in post no. 346 in Filing a Tax Return.

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Posted

Hi Panda,

Thanks for your amazing guides to these forms. :)

On the Anlage N-AUS, I'm wondering how I should do the currency conversion for foreign income and taxes. I worked in the US last year, and federal income tax, social security, etc was taken out of my monthly pay check (I've yet to file my US return). Should I perform the currency conversion for each month using the table in the Umsatzsteuer-Umrechnungskurse and add them up, or only once for the end of the year?

Best,

Ryan

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Posted

I would do it for each month.

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Posted

Thank you for this great topic.

One question, I have income in GBP, how can I enter this income in the taxation software?

Thanks in advance

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Posted

You should use these conversion tables to convert the GBP amount into €.

However, if you had this GBP employee income before you moved to Germany, then you do not fill it into Anlage N-AUS, but into line 99 of the Mantelbogen ESt1A.

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Posted

Hi All,

I am currently doing the tax return for 2012. I had worked from Jan 2012 - Feb 2012 in UK and then I moved to India( did not work there) and then came to Germany for work from Aug 2012.

Can please someone tell me how many forms am I supposed to send? Are all these 4 forms necessary for me to submit for my situation mentioned above? Or is there additional forms I need to do?

1) Mantelbogen ESt1A.

2) Anlage N

3) Anlage N AUS

4) Anlage Vorsorgeaufwendungen

Also Panda Munich - As per your last reply in March 2013. I see that u mentioned that one does not need to fill in anlage N Aus. I am bit confused if I need this form now for my situation or not?

"However, if you had this GBP employee income before you moved to Germany, then you do not fill it into Anlage N-AUS, but into line 99 of the Mantelbogen ESt1A."

Many thanks for your reply in advance.

Look forward to your response.

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Posted

Yes, you just need these 3 forms:



  1. Mantelbogen ESt 1A: enter your UK income into line 99
  2. Anlage N: for your German income from August 2012
  3. Anlage Vorsorgaufwand: for your German pension insurance, health insurance, and other insurances
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Posted

Hi All,

My situation is a bit different from the one described above but I'd like to know if someone has advices or is in a similar situation.

I'm living in Germany for a few years now and until 2012 I have paid my taxes in Canada. Starting with 2012, I will have to pay in Germany as I'm no more a resident of Canada. Note that my Employer is in Canada and the company doesn't have any office here. This is the situation described on this web page:

http://www.steuerliches-info-center.de/EN/SteuerrechtFuerInvestoren/Allgemeine_Informationen/Arbeitgeberpflichten/Arbeitgeberpflichten_node.html

So basically I have to take care of everything myself on the German side of the story. First thing will be to take care of taxes. Anyone knows which formular I should fill? Should I fill Anlage N-AUS? I have the impression that it applies only when someone works outside of Germany?

Many Thanks!

El Gitanito

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Posted

Hi PandaMunich, I have a question, but first, my details:

I started work in Germany last August 2012 as an employee and worked a total of 81 days in Germany up until Christmas (note: I registered in Germany for the first time in August of last year and continue to work here this year). For the first half of last year, I worked in Finland and had my tax return done over there for this half year. Do I need to declare this income in Finland in my German tax return? My understanding was that if you worked and lived in Germany for less than 180 days in that tax year, then I only pay tax on my German income and don't need to declare 'world income'. Does this hold the same in this situation and do I need to declare my Finnish income?

Thanks very much, you are a legend in these forums :-)

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Posted

Do I need to declare this income in Finland in my German tax return?

Yes, you have to declare your gross Finnish income in line 99 of the Mantelbogen ESt 1A.

My understanding was that if you worked and lived in Germany for less than 180 days in that tax year, then I only pay tax on my German income and don't need to declare 'world income'.

Now, wherever did you get that from?

You didn't understand correctly. Germany never taxes your Finnish income.

The German tax system works in the way that people who have higher yearly incomes and are there able to pay more tax, have to pay a higher tax rate.

So everybody is taxed according to his/her ability to pay.

They will add up your Finnish and German incomes that year, look up the tax rate that would be due on such a yearly income and apply that tax rate to the German income only.

So your Finnish income only means that you pay a higher tax rate than normal on your German income.

This is called progression.

You can calculate it for yourself by entering your German taxable income (= zu versteuerndes Einkommen) and your Finnish progression income (= Dem Progressionsvorbehalt ...) into this official progression calculator.

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Posted

Hi Panda,

Thanks very much for your reply....This is the source I found the 180 day rule:

http://www.taxrates.cc/html/germany-tax-rates.html

The sentences of note are:

Income tax is payable by German resident individuals on their worldwide income. Non-resident individuals are only required to pay tax on German-sourced income.

Individuals are deemed resident if they have a residence in or their customary place of abode is in Germany. The latter is the case if the individual has spent more than 180 consecutive days of the relevant year in Germany.

Its about the fourth 'paragraph' down. By residence, I took this as being a fixed home?? In the case of customary place of abode, which I deem myself the situation to be in, then in the 2012 tax year, I was in Germany for less than this 180 days.

What do you think??

Cheers

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Posted

You registered here, live in a flat (not in a hotel!), and you came here with the intention to stay

--> you are a classic case of being resident and therefore had unlimited tax liability in Germany from the moment you registered here.

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Posted

Thanks very much Panda. Wouou have by any chance, the notes for filling out numbers 61 to 82 in the 2012 Anlage N-AUS form?

You are a legend!

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Posted

You do not need the Anlage N-AUS, since you did not have the Finnish income during a time in which you were already resident in Germany.

At the risk of repeating myself:

Yes, you have to declare your gross Finnish income in line 99 of the Mantelbogen ESt 1A.

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Posted

Hi Panda,

First of all I would like to thank you for your great contribution to this community.

I have a question also about this Anlage N-AUS form. I think I am in the same situation as paulinmunich, but let me give you some details first: I moved to Germany in July 2012 from Romania, after finding a job here as a Software Developer. I registered my residence in Berlin at that time. Before this, for the first half of the year, I worked in Romania for two different companies and for my incomes I payed the taxes to the Romanian state.

I filled all the required documents on Elster Online but yesterday I received by post a letter asking me to fill in Anlage N-AUS and to send it back. Is this necessary in my case?

Thanks a lot!

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Posted

The Anlage N-AUS is only needed for the case that somebody had foreign employee income while being resident in Germany, this can either be:



  • most commonly: cross-border commuters who live in Germany but work in a neighbouring country (see here. To get to see the text click on "I want to become a fan", which is the exact opposite of what its says in German, so it's safe to click on it. GoogleTranslate comically translates "Anlage N-AUS" as "plant N-OUT", ignore that), or
  • the rare case: if your former employer only paid out your foreign salary after you were already officially resident (= angemeldet) in Germany.

Did you fill in line 99 in the Mantelbogen ESt 1A with your Romanian gross income (= gross salary + other source of income) that year?

If not, then they got suspicious and are asking for the Anlage N-AUS in order to get a detailed overview of your Romanian income, i.e. to find out whether a part of it was paid when you were already resident in Germany, which would mean that they would have a chance to also tax it here.

Because that's really all the Anlage N-AUS is:

  • You claim: "You don't have the right to tax my foreign employee income!"
    --> the Finanzamt says: "Before we can accept that we have no right to any tax on this income, please give us all the details (in the Anlage N-AUS) so that we can decide by ourselves. Who knows, maybe we do have a right to some tax on this income!"

In other words, in your case filling in the Anlage N-AUS will not give them any new information, since all your Romanian income was paid to you before you registered in Germany.

However, since they asked for it, you will have to submit it, no matter how useless it will be.

Just follow the instructions in post 3, and leave lines 61 to 83 empty, those are meant for cross-border commuters. Germany has a lot of different treaties depending on which country they commute to, so they need a whole page.

Important is that you attach:



  1. copies of your Romanian salary slips,
  2. of your bank slips (to show the entry of the Romanian salary before the date you registered here), and
  3. a copy of your Anmeldung so that they see from what date they had taxation rights on you.
That's what they really need, not the Anlage N-AUS.
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Posted

Hi PandaMunich

Amazing post, really helpful!

I am a little confused about how my circumstances fit into all this since I didn't need to actually go abroad to work.

I have been working and living in Germany for a few year. Last year I took on some work in my home country, the UK. I was paid for this work and taxed under the UK system.

Whilst the UK contract covered the whole year, I did hours on a flexible basis and only worked some hours in some months. Further, I never needed to actually go to the UK and could do all the work from Germany.

I am trying to declare this income in the N-AUS form, is this correct? I have followed the steps you provide but I am unsure about what to put in the days actually worked and days planned to work in the foreign country. Since I didn't actually work any days in the foreign country. I did visit the UK a few times through the year though. Can you help me with this issue?

Thanks a lot for your help in advance.

Best,

pocket_nines

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Posted

Just fill it in as best you can (fill in 0 days if you didn't spend any time in the UK on work assignment) and attach copies of all relevant documentation, including proof of the UK tax you paid.

They will ask extra questions in a letter if they still have doubts.

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Posted

Hi Panda, thanks a lot for your quick response!

I am still a little unsure though. I am currently putting in about 200 days where it says "46. Vertraglich vereinbarte Arbeitstage im KalenderJahr" because my contract covered the whole year and then I put 0 in where it says "47. davon entfallen auf die Tätigkeit, für die der ausländische Staat das Besteuerungsrecht hat". 0

If I do this then the calculator says I do not have to pay any extra tax no matter how much I earned abroad. This doesn't seem right to me...

I just don't want to end up with any unpleasant surprises.

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Posted

Point 47 asks for the number of days that the UK had the taxation rights on.

It will end up being a different number, but you start by playing dumb and claiming that you thought the UK had the taxation rights.

In fact, as you describe the situation, that income shouldn't have been taxed in the UK at all, but in Germany.

But as I said, play dumb, you are acting in good faith and are simply describing what happened.

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