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BFH Ruling: Germany Can Tax Pensions of NHR Retirees in Portugal

The ruling applies the treaty’s subject-to-tax fallback to pensions left untaxed in Portugal.

Overview

  • Germany’s Federal Fiscal Court held that Portugal’s non-habitual resident regime does not block German taxation where Portugal imposes no tax on the pensions.
  • The decision covers pensions from professional pension schemes and, according to the court, also extends to German statutory social-security pensions under the same treaty provision.
  • Administration for nonresident pension taxation is centralized at Finanzamt Neubrandenburg, which can order source withholding of about 25 percent that may be reduced on request.
  • Retirees affected in Portugal should expect possible reassessments and seek advice, noting typical assessment periods of four years or five years for negligent understatement and the option of voluntary self-disclosure.
  • Portugal’s NHR rules grant a ten-year full exemption for pre–April 1, 2020 entrants and a 10 percent rate for later entrants, but Germany may tax where Portugal does not actually levy tax.