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If I move to Germany, which tax jurisdiction will I be under?

Question:

If a director of a UK Ltd company moves to Germany, what is their tax position regarding PAYE income and dividends from the company, i.e., where would they pay tax on these? 

Arthur replies: 

Once you move to Germany and become tax-resident there, all your worldwide income (including salary and dividends) falls into the German tax net. Under the UK–Germany treaty, employment income (PAYE salary) for duties performed in Germany is taxable only in Germany (Article 14) (the UK retains the right to tax any days you continue to work in the UK – but this has particular rules). Dividends paid by your UK company to you as a German tax-resident are taxable only in Germany (Article 10). The UK does not withhold tax on dividends. 

If a director of a UK Ltd company moves to Germany, what is their tax position regarding PAYE income and dividends from the company, i.e., where would they pay tax on these? 

Arthur replies: 

Once

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This question was first printed in Business Tax Insider in June 2025.