Moving from the UK to Germany — Post-Brexit Comprehensive Guide for Expats

Post-Brexit Legal Status for UK Nationals in Germany

The UK left the EU on 31 January 2020 and freedom of movement ended on 31 December 2020. UK nationals are now treated as third-country nationals under German and EU law — identical to US, Canadian, or Australian citizens. Those who registered with German authorities before 30 June 2021 received the Aufenthaltsdokument-GB confirming their Withdrawal Agreement rights. This document is permanent and does not expire. Everyone who arrived after that date must obtain a standard German residence permit.

Residence Permits for UK Nationals Arriving Post-2021

UK nationals arriving after December 2020 must apply for a German residence permit (Aufenthaltserlaubnis) at the local Ausländerbehörde before the 90-day Schengen period expires. The correct permit depends on your purpose. Germany is generally open to skilled professionals from the UK — the key is matching the correct permit category to your situation and having documents ready before the clock runs out.

• EU Blue Card (§18g AufenthG): degree + salary ≥€48,300/year; fastest path to permanent residence (21 months with B1 German)
• Skilled worker permit (§18a/18b AufenthG): recognised qualification + job offer; employer usually initiates application
• Self-employment (§21 AufenthG): viable business plan, IHK assessment, proof of financing; up to 3 years initially
• Chancenkarte (§20a AufenthG): new 2024 — points-based entry without job offer for qualified applicants; 12-month search period
• Family reunification (§28/§30 AufenthG): joining a German citizen or holder of permanent residence with adequate income

Tax Implications for UK Expats Moving to Germany

The UK-Germany Double Taxation Agreement (DTA, 2010) is fully in force and unaffected by Brexit — it prevents double taxation on income earned in both countries. German tax residency begins when you establish a home available to you at any time (AO §8) or exceed 183 days of physical presence in a calendar year (AO §9). From that point, all worldwide income must be declared in Germany, with DTA credits preventing double payment.

• UK employment income: taxable in Germany; credit given for UK PAYE already paid under DTA Article 15
• UK rental property: taxed in UK under DTA Article 6; declared in Germany but credit given for UK tax paid
• UK private pension drawdowns: taxed in Germany (country of residence) under DTA Article 17
• UK state pension: allocation depends on DTA Article 17 provisions — seek specialist advice
• UK dividends: up to 15% withholding tax in UK under DTA; credited against German Abgeltungsteuer at 25%
• Germany has no split-year treatment — residency begins from day one of establishing a German home

Health Insurance: Transitioning from NHS to German GKV

UK nationals moving to Germany cannot use the NHS for ongoing healthcare after establishing German residency. The EHIC/GHIC card covers emergency treatment on visits to EU countries but does not substitute for German health insurance for residents. German health insurance is compulsory from the date of Anmeldung under §5 SGB V. If you arrive without cover, the insurer must enrol you retroactively and may charge backdated premiums.

• GKV (statutory): income-based contribution ~14.6% + employer Zusatzbeitrag supplement (~1.6%); free dependant cover
• PKV (private): available to self-employed and employees >€73,800/year; risk-based premiums; no free dependants
• Major GKV providers: TK (Techniker Krankenkasse), AOK, Barmer — TK and Barmer offer English customer service
• Zahnzusatzversicherung: supplementary dental insurance recommended; GKV basic dental cover is limited
• Warning: once in PKV, returning to GKV later in life is severely restricted — consider carefully before choosing PKV

Banking in Germany for UK Expats

UK bank accounts remain useful for international transfers but German employers and landlords require a German IBAN. Many UK banks close accounts of customers who permanently establish non-UK residency — check your terms before the move. HSBC Premier, Barclays International, and NatWest International typically accommodate overseas residents; standard high-street accounts (Lloyds, Halifax, Santander UK) often do not.

• N26: fully online German bank; accepts UK passport + Anmeldebestätigung; English interface throughout
• Commerzbank: free account with €700/month regular inflow; in-person VideoIdent or branch verification
• Deutsche Bank: comprehensive services; in-person visit required; best for large existing wealth
• Wise: German IBAN with simultaneous GBP/EUR accounts; ideal for managing both UK and German finances
• SCHUFA: no UK credit history transfers to Germany — you start fresh; this limits credit and store cards initially

Recognition of UK Qualifications in Germany

Post-Brexit, UK professional qualifications are no longer automatically recognised in Germany. Regulated professions must apply for formal recognition through the relevant German Kammer or Landesbehörde. The EU-UK Trade and Cooperation Agreement (TCA) does not provide automatic mutual recognition — it only establishes a framework for future profession-specific agreements, few of which are yet concluded.

• Medical doctors: apply to Landesärztekammer (state medical chamber) in the Bundesland where you will work; 3–6 months processing
• Dentists/pharmacists: apply to Landesapothekerkammer or Landeszahnärztekammer respectively
• Architects/engineers: apply to Architektenkammer or Ingenieurkammer of relevant Bundesland
• Lawyers: UK solicitors can only practise EU law as a European Lawyer (EuRAG §2); German law requires full Zulassung from Rechtsanwaltskammer
• Portal anerkennung-in-deutschland.de: comprehensive guide to all recognition procedures and responsible authorities

UK Businesses Operating in Germany Post-Brexit

Post-Brexit, UK companies lost EU single market passporting and freedom of establishment. A UK company providing goods or services to German customers on an ongoing basis may need to establish a German subsidiary GmbH or registered branch (Zweigniederlassung) to maintain compliant market access. Repeatedly conducting activities in Germany without a formal establishment creates Betriebsstätte (permanent establishment) risk under AO §12, triggering German corporate tax on attributed profits.

• Goods exports UK → Germany: full EU customs procedures — EORI number, ATLAS declaration, customs duty, 19% Einfuhrumsatzsteuer
• B2B services to German clients: generally no import VAT, but customer may need to apply reverse charge under §13b UStG
• Financial services: UK firms lost EU passporting — BaFin authorisation required under KWG, ZAG, or KAGB
• German GmbH subsidiary: cleanest solution for ongoing presence — €25,000 minimum capital; 3–6 weeks setup
• Branch office (Zweigniederlassung): faster/cheaper; parent company bears unlimited liability

Importing Your Car and Household Goods from the UK

UK nationals permanently relocating to Germany can import household goods and their personal car duty-free under the Übersiedlungsgut (personal effects) exemption, provided the items were owned and used for at least 6 months before the move. The move must be completed within 12 months of first establishing German residency. Declaration is made to German Zoll using the EU personal effects procedure.

• Household goods: C384 declaration to Zoll; no import duty or VAT if conditions met
• UK-registered car: re-register in Germany within 6 months of arrival at Kfz-Zulassungsstelle
• Car re-registration requires: TÜV Hauptuntersuchung (roadworthiness), German Kfz-Haftpflichtversicherung, payment of annual Kfz-Steuer
• UK driving licence: valid for 6 months after establishing German residency; then exchange at Führerscheinbehörde — no re-test under EU-UK TCA exchange framework
• Right-hand drive cars: legal to drive in Germany; however resale value is significantly lower and some UK-spec features (e.g. fog lights) may need adjustment for German TÜV

German Naturalisation for UK Nationals

UK nationals who have lived lawfully in Germany for 5 years can apply for German citizenship under §10 StAG. Since the Staatsangehörigkeitsgesetz reform of 26 June 2024, multiple citizenship is broadly permitted — UK nationals can retain their British passport when naturalising as German. This is a significant change: prior law required renunciation of UK citizenship in most cases, which deterred many UK nationals from naturalising.

• 5-year lawful residence: all permit types count from first day of validity
• B1 German language: certificate from Goethe, telc, ÖSD, or TestDaF required
• Einbürgerungstest: 33 multiple-choice questions; minimum 17 correct; €25 fee; questions publicly available at bamf.de
• Financial self-sufficiency: no current receipt of Bürgergeld (SGB II) without good cause
• Dual citizenship: UK passport retained after German naturalisation under 2024 StAG reform
• Processing time: 12–24 months in major cities; apply as early as the 5-year threshold is reached

UK-Germany Social Security Convention

The UK-Germany Social Security Convention (maintained post-Brexit) coordinates social insurance contributions and prevents double coverage between the two countries. For UK nationals working in Germany, this is particularly important for pension coordination and posted worker situations. The Convention covers: pensions, sickness, maternity, work accidents, unemployment, and family benefits.

• Posted workers: UK employees sent to Germany for up to 24 months remain in UK National Insurance (NI); employer obtains Certificate of Coverage from HMRC
• UK NI years: count toward German pension qualifying periods (Wartezeiten) — minimum 5 years needed for any German Rente
• UK state pension: continues to accrue from NI contributions; voluntary Class 3 NI (~£17.45/week 2026) can maintain UK pension while living in Germany
• German Rentenversicherung: compulsory for all employees; 9.3% employee + 9.3% employer contribution rate
• Private UK pensions (SIPPs): cannot be transferred to German schemes; taxed in Germany upon drawdown under DTA Article 17