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Germany Can Tax Portugal-Based German Pensions, Top Court Rules

A treaty fallback shifts pension taxation to Germany in cases of Portuguese non-taxation.

Overview

  • The Federal Fiscal Court’s 3 September 2025 ruling holds that pensions received by residents using Portugal’s residente não habitual status fall under the double-tax treaty’s subject-to-tax clause.
  • The decision covers payments from professional pension schemes as well as statutory social insurance, rejecting claims that these should be treated differently.
  • In the reported case, a retiree living in Portugal received a German tax assessment of €82,521 for 2019 after Portugal waived tax under the special status.
  • German authorities, led by Finanzamt Neubrandenburg, are positioned to apply the judgment, including ordering about 25% withholding at source on pension payments to residents abroad.
  • Experts say the reasoning may be applied to other countries with newcomer tax incentives, and retirees should review their exposure given Portugal’s pre‑April 2020 full exemption and later 10% regime.