Taxation of Swiss retirement savings pillar 3a
February 7, 2017 | 100,00 EUR | answered by StB Patrick Färber
I have been living in Switzerland for 7 years and will be relocating back to Germany this year, where I will also work again. I have taken advantage of the opportunity to make voluntary payments into a pension account. In Switzerland, this is the 3rd pillar of retirement savings (pillar 3a). The contributions to this account are limited in amount and have a tax-reducing effect. Now, there is the possibility to withdraw the entire balance due to emigration. To do this, an application must be submitted along with a deregistration confirmation from the Swiss municipality and a registration confirmation from the German municipality. Therefore, the withdrawal will only take place after leaving Switzerland. The balance is subject to withholding tax in Switzerland. Will this pension balance be taxed again in Germany? If so, does this depend on the timing of the withdrawal?
Dear inquirer,
Regarding capital that has been deposited into the 3rd pillar in Switzerland, according to German understanding, this usually refers to assets whose earnings are classified as income from capital assets (and not pensions like in the 2nd pillar). However, it depends on where and in what form the deposits were held for you (bank, insurance, funds, etc.).
The transfer of the monetary assets themselves to Germany is not a taxable event. You are transferring assets across borders. In case of high transfer amounts, the AWV notification must be observed. Therefore, the source taxation in Switzerland remains in place. To my knowledge, balances from the tied pension 3a can only be withdrawn at least 5 years before the start of AHV pensions.
From the point of becoming subject to unlimited tax liability in Germany, any potential earnings from this asset, which you may reinvest, will be taxable in the form of interest, dividends, etc.
I hope this information has been helpful to you.
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