Keep a home in Germany or stay more than six months and Germany taxes your worldwide income — pensions included. The good news: the US treaty is unusually clean on Social Security, and there's no wealth tax. Here's what applies in 2026.
Last verified: 8 July 2026Germany uses a continuous formula rather than stepped brackets — your marginal rate climbs smoothly from 14% to 42%. These are the 2026 zones for a single filer (double every figure for a jointly assessed married couple):
| Taxable income (single) | Marginal rate |
|---|---|
| Up to €12,348 | 0% (Grundfreibetrag) |
| €12,349 – €69,878 | 14% rising progressively to 42% |
| €69,879 – €277,825 | 42% |
| Above €277,826 | 45% ("Reichensteuer") |
The solidarity surcharge (5.5% of the tax bill) now only bites above a high exemption threshold — roughly €20,350 of assessed tax for a single filer in 2026, which corresponds to well over €100,000 of income. Most retirees pay none.
Germany taxes pension income on a cohort system: for pensions first drawn in 2026, 84% of the pension is taxable and 16% is fixed as a permanent tax-free amount (the taxable share rises 0.5 points per start-year cohort, reaching 100% in 2058). Combined with the €12,348 allowance, a modest pension can owe little or nothing.
For Americans, the treaty answer is unusually clean: US Social Security paid to a German resident is taxable only in Germany (US–Germany treaty, Art. 18(5)) — Germany treats it like a German statutory pension, taxable-portion rules included. Everything else — IRAs, 401(k)s, Roths — is genuinely unsettled in German practice. Nobody can honestly tell you the settled answer, because there isn't one.
| United States | Canada | |
|---|---|---|
| Keep filing? | Yes — the US taxes citizens on worldwide income wherever they live. Foreign tax credits (German rates usually exceed US rates) or the FEIE eliminate most double tax. | Generally no, once you cease Canadian tax residency — but watch departure tax on deemed disposition of assets when you leave. |
| Treaty | US–Germany treaty in force. Social Security: taxable only in Germany (Art. 18(5)). Private pensions and accounts: complex — get advice. | Canada–Germany treaty in force. CPP/OAS have source-country rules; the precise treatment is case-specific — get cross-border advice before you move. |
| Social security credits | Totalization agreement since 1 December 1979 — no double contributions; US and German credits combine for benefit eligibility. | Canada–Germany social security agreement in force — CPP/OAS coordinate and export. |
Social Security (settled), IRAs and Roths (not settled) — what to ask a cross-border adviser, and when.
ELSTER, the Steuerberater question, deadlines, and what a retiree return actually contains.
Departure tax, deemed disposition, and what happens to CPP, OAS and RRSPs when you become German-resident.
US and Canadian tax obligations don't stop at the border. We'll match you with a cross-border tax adviser we've checked ourselves — credentials, licensing, and real client outcomes in Germany.