Tax non-resident · UK · post-Brexit

Moving to Germany from UK – Buying a house in Germany from the UK: did Brexit make it harder?

Staying in Britain and buying German property, or planning the move? Buy a house in Germany from the UK: third-country status after Brexit, GBP income and how German banks assess the application.

Brexit or sterling: what decides a German mortgage from the UK today?

Brexit itself now makes little difference to a German mortgage from the UK, and it has in fact improved the picture. Since Brexit took full effect in 2021, a UK residence is assessed under each bank’s ordinary country rules, so more lenders accept it. Income in sterling is credited with a safety discount of 10 to 50 %.

Living in the UK: which German lenders will finance you?

For Germans living in the UK, Brexit has widened rather than narrowed the choice of German lenders.

Is income in GBP accepted for a German mortgage? Yes, at specialist banks, with a discount of 10–50 % on the income converted into euros, depending on currency and type of income. UK tax documents such as the P60 and SA302 are accepted as proof of income. The document checklist.

How much equity do I need with a UK residence? Up to 40 % depending on the case, plus incidental costs — the range depends on income type and credit standing; with a UK residence it is usually higher than for a German residence because of the foreign-risk surcharge. Calculate the closing costs.

UK residence post-Brexit

With a UK residence, GBP income is possible at specialist banks, equity is up to 40 % depending on the case plus incidental costs, and the choice of banks is larger than before Brexit.

GBP Possible at specialist banks; up to 40 % Equity depending on the case, plus incidental costs; Larger Choice of banks than before Brexit.

Income in GBP — what's possible: GBP income: possible at specialist banks, with a discount of 10–50 % on the income converted into euros; UK tax documents (P60, SA302): accepted as proof of income — English is standard; Employer: stable corporate employment is preferred; the self-employed in the UK have a smaller circle of banks;

Equity: up to 40 % depending on the case, plus incidental costs — with a UK residence usually higher than for a German residence because of the foreign-risk surcharge; Notary appointment: travelling in person (visa-free with a German passport) or a power of attorney with apostille.

Why do many banks still decline sterling income?

Leaving the EU did not make it harder to buy property in Germany. Purchase and land registry entry are open to anyone, regardless of nationality or country of residence. What narrows the pool of lenders here has nothing to do with Brexit: it is the pound.

If you live in London, you live outside the eurozone — but, since Brexit, also outside the EU. What decides the case is the currency risk of sterling income: lenders absorb it with a discount of 10–50 %, depending on currency and type of income. That many banks still decline is down to internal country lists and processing effort.

Three practical points

Three points matter: a residence in Germany changes the starting position but carries significant tax consequences, lenders apply a safety discount to sterling income, and UK evidence needs to be prepared and explained.

The residence lever. Establishing a residence in Germany changes the starting position — but it carries significant tax consequences, because a residence within the meaning of § 8 AO can trigger unlimited German tax liability.

This is not a trick; it is a decision with consequences. We explain the mechanism; the tax assessment belongs with a tax adviser.

The income haircut. Lenders that do accept sterling income apply a safety discount to it — over a twenty-year term an exchange rate can travel a long way.

That reduces recognised income noticeably and belongs in the budget from the outset, not in the disappointment at the end. Evidence. Payslips, P60s and Self-Assessment returns are perfectly valid proof, but they are unfamiliar formats to a German bank.

They need to be prepared and explained, or the assessment stops before anyone has looked at them properly.

Moving to Germany from UK or staying in Britain: what changes for the mortgage?

Since Brexit the UK counts as a third country: German banks assess GBP income and a UK residence differently — which bank accepts it decides the case.

Moving to Germany changes that starting position, but a German residence within the meaning of § 8 AO can trigger unlimited German tax liability — the tax assessment belongs with a tax adviser.

Frequently asked questions

Living in the UK: which German lenders will finance you?

For Germans living in the UK, Brexit has widened rather than narrowed the choice of German lenders.

Is income in GBP accepted for a German mortgage?

Yes, at specialist banks, with a discount of 10–50 % on the income converted into euros, depending on currency and type of income. UK tax documents such as the P60 and SA302 are accepted as proof of income.

How much equity do I need with a UK residence?

Up to 40 % depending on the case, plus incidental costs — the range depends on income type and credit standing; with a UK residence it is usually higher than for a German residence because of the foreign-risk surcharge.

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