Working in UK while living in Germany

Hi all,

Arrived in Germany (Munich) last Saturday and I'm just organising my registration with the authorities.

I'm in a pretty complex situation. I work for a company in the UK and for the last 9 months or so I haev been travelling around. Up until a few weeks ago I had spent my time in Australia. Now I am here I'm really not sure what to do in regards to tax etc.

On the registration form it asks if you are employed, I guess I should say yes. What happens then? Does anyone know an english speaking accountant that I can go to about this? Should I just say no for the moment, and sort this out at a later date? I have a british passport, so there should be no problems with residency or employment for that matter.

Does anyone have any experience with this and the best way to handle it?

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Hi AndrewH,

I am in a similar situation as you and am employed by a company I own based out of Toronto, Canada. Like you, I am also a British citizen but travelling to Germany (Berlin) from abroad.

I think that if you are employed somehow, that you should state that in your registration where your income comes from. It can only get ugly if they find out otherwise after you state "no" to being employed.

I know that we as Brits have the right to work and live throughout the EU, but that means if you can support yourself without the assistance of the government.

My first instinct would be to tell them the truth... if they require more information, that's when you should go about talking to an accountant.

Best of luck

Related situation. I am planning to move to Munich in the new year though I will continue to work and be paid in London by a UK Company. I will be in the UK for 9 days followed by 12 days in Munich (homeworking).

I would like any help you can provide relating to the following. i have tried to follow some of the other threads but can't find anyone who is travelling backwards and forwards and yet still gets paid in the UK. Don't know if it makes any difference but I'm British.

Tax - Can I avoid paying any tax in Germany seeing as I will continue to pay tax in the UK?

Health Care - Any idea what I need? I presume an E111 or tourist health insurance won't cover me if I'm working in Germany

Registration - Do I need to register in some way?

Many thanks
Nick

I guess you must have reasons for doing it but it will probably make things a bit complicated paper work wise. Here are my thoughts (no guarantee they are correct)

you'll be in Germany for more than 6 months a year so should pay tax in Germany in theory. May be able to avoid it due to double taxation treaty though.


I doubt it will cover you for such long periods in G. I thought you would be officially 'working' in UK?

I should think so as you are here more than 6 months per year

only by being in the country for 180 days or less.


E111 is for emergency cover for tourists only. It is not designed for long-term stays. Get your employer to pay for exra private medical cover. Most good UK companies will do this.


only if you plan to be here for longer than 3 months, then you have to register.

Gotta be real quick but I was paid from London and so paid tax there. Healthcare - you'll need BUPA Gold International or something - about £1,000 for a year for me I think (or was it £500 - can't remember).

Yes - you'll need to register, but your company MIGHT pay for that - it'll save hassle if they will. Haidhausen's nice, but personally (and I was a the time a young single man) I couldn't recommend Schwabing highly enough - horses for courses though.

G'night.

I live in Munich and work in London. I've been doing it for the last 5 years commuting 3-4 times/month on average.

Tax - You are allowed a maximum of 90 days in the UK before paying UK tax. There 'appears' to be no restriction on Germany as you don't work/earn any money here (just spend it). When I started out I paid mega-€'s to an 'International Tax Consultant' for an explanation of the German Tax Law. It may change however with time. If you claim to be non-resident in the UK, you WILL be audited so keep good records.

Healthcare - I agree with Owain... E111 not recommended. I use AXA in the UK (European policy) which covers me for medical. Paperwork is proving a problem though as the german doctors are reluctant to fill out the AXA claim form (german)...which needs to be translated back into english. Costs around £75/month.

Registration - 'Anmeldebestätigung' required from Landeshauptstadt München. Not sure about the other stuff.

Declan

You will almost certainly pay all your tax in Germany, but will have to submit a return to the Germans showing your income and expenditure. If your taxable liability in Germany is less than the UK; and you can show you have paid tax to the UK taxman, then there will be no tax to pay. If your taxable liability is higher, you may have to pay the difference. HOWEVER given the allowances you will be able to claim in Germany as a result of having two homes (not applicable in the UK I believe), then your liability may be less, and you may be able to pay German tax and avoid UK tax... The general rule is you won't be taxed twice...

It's complicated, however - you should seek professional advice from someone familiar with the situation...

YL6

Thanks for the help. This is all useful (though I'm now more confused)

Sounds like both the tax and the health care could be an issue.

I will be officially working in the UK and the time in Munich is my own choice (i'm not being asked to work in Germany), therefore I'm unlikely to get my Company to pay for any health care cover. I guess I'll have to look into that AXA thing a couple of you mentioned. Sounds quite steep though considering I would only go in an emergency as I have a doctor in the UK I could see for non urgent stuff.

Tax sounds very complicated. I will obviously be out of the UK for more than 90 days (though never in one go?) - I presume its an annual total? I also guess German Income tax is higher than UK so I'm not sure I could afford that. Also its taken straight from my salary so how would I get the UK bit back if I got a huge bill in Germany? Looks like i need a tax advisor!

Thanks all.

you presume right


pure income tax is actually lower in Germany I think. However in Germany there are a number of add ons such as pension insurance (like national insurance) and the solidarity tax to pay for East Germany (isn't very much), so the total amount drawn from the pay packet is more in Germany (especially if one chooses to have the health insurance withdrawn at source). Not sure if you would have to pay pension insurance etc - you probably do I guess

He doesn't have to pay health or pension insurance as his income is not from a German employer - this is an income while resident in Germany, but from an external source...

As far as the insurance is concerned, I'd be inclined to buy an annual travel policy, just to solve emergency problems and get you back to Blighty if something serious happens, like an accident... These aren't expensive, as they are not permanent health care, like the others...

Hello!

I am evaluating the possibility of living in Berlin, but commute to London for work (3days a week). My husband got a job in Berlin and in case I do not find one this can be an option for a while. Has anyone been in similar situation? Will I be taxed in Germany or UK? Is this type of commute to work tax deductable?

Thanks in advance!

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Yours is quite interesting as you say you will commute to London for work 3 days a week.

The quick rough guide people normally talk about is the 183 day rule - so wherever you spend the greater part of 6 months of the year should be your tax domicile. But like everything it is not that simple.

Your COMMUTING days do not count. So for instance if you fly to London on Monday morning, and fly home Wednesday evening you have been in London for tax purposes 1 day. This is normally advantageous for those that wish to NOT be in the UK for tax purposes, although in your case of course it would be better to be taxed in the UK usually.

So based on that it sounds like 99% you will be taxed in Germany. Furthermore the rules are complicated by your main residence status. Again this sounds like it will be in Berlin, and if your husband also lives and works in Germany it will be even harder to argue that your main residence is the UK.

Single people with 2 rented places (1 in UK, 1 in Germany) can play the system a little better. But for those with spouses in Germany it is pretty hard to argue that your main base is the UK.

p.s. I am pretty sure your commute would be tax deductible - travelling expenses for work purposes.

What Johnny English Said is true but no one checks up on this things that much (in my experience) 3.5 years working in the UK but living in Germany

So if you are on the border and take a few holidays in the UK you can effectively decide which one you prefer. At the moment I'm defo 183 days in the UK. But in my last job I had, I was on the border but still opted for the UK - If you are paying tax in one country the tax authority tend to leave you alone (from what I understand)... Double Taxation treaty or something.

A great advantage with the UK is there is no official registration so you can use a family members place as your official residence as well...

PS. I'm Married in Germany but still pay taxes in the UK - again no problems...

Forgot to add the rules are so stupid that I can play with them - so I claim my travelling expensives (flights/trains/taxes/metro) for travelling from home in Germany against my UK tax but live in the UK so pay tax there!!! Isn't that a bit weird...

In fact I just realised if I wanted to I could use the travelling days and then decide to pay tax in Germany since it would then be 3 days in the UK and 4 days in Germany but eh I prefer it the way it is...effective tax rate aprox. 20% at the moment...

Well obviously you can bend, twist and bugger about with the rules as much as you wanna personally risk. Boris Becker got caught but the guy was earning serious money, dodging serious tax, and one of his fans sent the taxman newspaper cuttings that showed his locations during the year!

But my short humble experience with the German authorities so far is that they are pretty damn fierce and anal from Day 1.

I am just trying to give a semi-official side of the rules. For instance if you don't know the rules then you are liable to do something dumb like submit a whole bunch of airline receipts as expenses that in themselves PROVE you have not been in the UK for enough time.

STANFORD - I am sure you do prefer paying tax in the UK!

Just checked the official HM TAX website for confirmation in the UK:

http://www.hmrc.gov.uk/pdfs/ir20.htm#residence

Correct Johny English...I wound't want any one to get anyone into trouble...

And each will decide on how they use these rules...

Stanford remembering how easy it is to create Ryanair and Easyjet tickets in word...!!! I never said that... Anyhow much dash flight to get - to get home to nice Munich.

Take care Johnny English and have a good weekend

Re: Medical I would say take the (cheapest) option with BUPA International or with AXA etc. We had a yearly travel policy which did not cover us. Since using BUPA they have been superb and def. worth the extra cost for piece of mind imho.

Just a question. Although well qualified I found it difficult to get work in Germany and just wondered if anyone can give me some ideas on UK companys who might offer working from home positions that could be done from Germany. It looks as if I'll be moving back with OH job sometime in the not too distant future.

Cheers.

@speedygonzi

To be honest, if I was in your situation, I would just claim the UK as your main residence and make it out as though you just travel on weekends to see your husband. Of course, if they caught up with you, they might make you pay tax in Germany because you are techincally here longer, however due to double tax treaties, you wouldn't really have to pay that much. The chances of this happening though are pretty slim.

If you can get your work to pay you tax free though, and become a freelancer here, you would probably end up paying less tax in Germany than in the UK.