Most searches for moving to Germany from the UK begin with visas. That is only step one. Three decisions shape everything else. Can you live and work there? What happens to your UK company? How will each country tax you? This guide covers all three, using the rules in force in October 2026. 

Can UK Business Owners Move to Germany After Brexit? 

Yes, but not freely. Free movement ended with Brexit. You can move to Germany from the UK without a visa, but you cannot start work until you have a residence permit that allows it. 

Do UK Citizens Need a Visa or Residence Permit? 

British citizens can enter Germany visa-free. They then apply for a permit after arrival. The German Missions in the UK say you must register your address within two weeks. You then have 90 days to apply at the local immigration office. 

You may trade only if a permit explicitly allows it. Visa-free entry is not permission to work. 

Some people keep Withdrawal Agreement rights, usually from living in Germany before 2021. Check your status first. 

What Are Germany’s Visa Requirements for Business Owners? 

There is no special “business owner visa”. Germany’s business visa requirements instead follow the self-employment permit. The rules differ by type of work. 

Freelancers, such as consultants, need a business plan and proof they can support themselves. Commercial entrepreneurs face a tougher test. Officials look at economic interest or regional demand, the benefit to the economy, and secured funding. Applicants aged 45 or over must also show adequate pension provision. 

In Germany, the first permit lasts up to three years. The fee is no more than €100. If you search for a Germany visa for UK business owners, this is the route you want. 

How to Move to Germany from the UK as a Business Owner 

Order matters. Settle UK duties first. Then register quickly on arrival. 

What Must You Register After Arriving in Germany? 

Register your address first. Then apply for your permit. Commercial businesses register with the local trade office. Freelancers register with the tax office, which issues your tax number. VAT registration follows if needed. 

Anyone moving from the UK to Germany should also arrange health insurance early. The permit application asks for proof. 

Can You Keep Your UK Limited Company After Moving to Germany? 

Yes. Your company stays a UK company wherever you live. Moving house does not change where it was formed. The real question is different. Will Germany start treating it as its own taxpayer? 

Can You Live in Germany While Running a UK Ltd? 

You can stay a director from abroad. Your duties continue. The company needs a UK registered office. It must file its confirmation statement and accounts. Every director needs a verified identity. Many owners keep their UK limited company compliance running through a UK accountant while they are abroad. 

Could Your UK Company Become Taxable in Germany? 

It could. Two ideas matter. 

First, a company can be taxed where its effective management is located. That is where senior decisions are made. Run a UK Ltd from your Berlin kitchen table, and Germany may say it is managed there. Rödl and Partner note that the UK and German treaty gives residence to that state. 

Second, a permanent establishment is a fixed place of business, or an agent who habitually signs contracts. A regular home office can raise this question. 

Neither risk is automatic. Both turn on facts. This is where UK businesses moving to Germany often go wrong. Owners assume UK incorporation settles it. 

Should You Keep Your UK Ltd or Establish German Operations? 

You have four broad options: 

• Keep the UK Ltd and manage it with care. 

• Form a German company, such as a GmbH or UG. 

• Open a German branch of the UK company. 

• Restructure, for example by closing one company and starting another. 

The best fit depends on where customers sit, who makes decisions, and your long-term plans. Want to move the UK company to Germany in full? Moving the owner does not move the company’s legal home. That is a separate project. 

Serving UK clients is usually fine. The tax question is where you do the work, not where the client lives. 

Where Will You Pay Tax After Moving from the UK to Germany? 

Probably in both countries, though not twice on the same income. Treaties exist to stop that. Your job is to map which income goes where, ideally as part of proper tax planning before you leave. 

When Do You Become a German Tax Resident? 

German law uses two tests. One is a home available to you in Germany. The other is a habitual abode there. A home you keep and use usually makes you resident from day one. A habitual abode generally means staying for more than six months. 

That is why people misread the 183-day rule. It is a UK residence test and, in the treaty, a test for employment income. It is not a German starting gun. Most owners who rent a flat are resident at the same time. For Germany tax residency for UK citizens, think home first and days second. 

Will You Still Pay UK Tax After Leaving Britain? 

Possibly. The UK Statutory Residence Test decides if you are UK resident for a tax year. If you leave partway through, split-year treatment can divide the year in two. One part is UK. The other is overseas. 

Some UK income stays taxable anyway, such as rent from UK property, which is where specialist landlord accounting support helps. That is the core of UK tax when moving to Germany. 

Directors face an extra trap. Under the temporary non-residence rules, some dividends from a close company can be taxed in the UK if you return within five years. HMRC’s manual says dividends linked to pre-departure profits are the main concern. 

How Does the UK Germany Double Taxation Treaty Work? 

The agreement determines which state has jurisdiction to impose the taxes for the respective category of income. The other state has to provide relief accordingly. The agreement was signed in 2010, while in 2021 an additional protocol providing anti-avoidance measures was agreed upon. 

While addressing UK-Germany double taxation matters, consider the following three factors: relief is not automatic, you might file returns in both states, and the agreement just allocates taxes but does not exclude them. Our international and offshore accounting team deals with these cross-border filings regularly. 

The UK does not withhold tax on dividends paid by UK companies. Germany taxes its residents on their worldwide income. That is why, in most cases, dividends from your UK company will appear on your German return. 

What Happens to UK Director Salaries and Dividends? 

Each income type is treated differently. 

• Salary: work done in Germany is usually taxed there. It may trigger German payroll duties. 

• Director fees: the treaty can give the UK a taxing right, so review these separately. 

• Dividends: taxed where you live. The UK temporary non-residence rule is a risk. 

• Company profits: taxed where the company is resident. That is the question above. 

Should You Keep Your UK Ltd or Set Up a German GmbH, UG or Branch? 

Keep the UK Ltd if management genuinely stays in the UK. Consider a German company if you will live and operate in Germany long term, and our business setup in Germany service can help you compare the structures. 

How Much Does German Business Formation Cost in 2026? 

Split the German business setup cost into two parts. Share capital is not a fee. It stays in the company. A GmbH needs at least €25,000, with €12,500 paid in before registration. 

Formation costs sit on top. They cover the notary, the commercial register, and advice. Published estimates vary. Many land between roughly €800 and €2,500. Online notarisation can suit owners still abroad. 

What Are Germany’s Business Tax, VAT and Accounting Requirements? 

What Taxes Do Businesses Pay in Germany? 

A German company pays 15% corporation tax, plus a solidarity surcharge on that tax. It also pays trade tax, set by the local town. Freelancers in liberal professions usually pay income tax instead and avoid trade tax. 

There is good news ahead. A 2025 law cuts the rate to 14% in 2028. It then falls one point a year until it hits 10% in 2032. That may shape your choice of structure. 

Do UK Businesses Need German VAT Registration? 

It depends on what you sell, who buys it, and where you are established. Once you live and work in Germany, you may count as established there. That changes your invoicing, and it is worth reviewing alongside your UK VAT return position. 

Germany VAT for UK businesses also touches the small business scheme. Since 2025, it applies when last year’s turnover was €25,000 or less. This year’s turnover must also stay under €100,000. Check eligibility before you rely on it. 

What Accounting and Electronic Invoicing Rules Apply in 2026? 

Germany’s accounting requirements depend on the business owner’s legal form. A GmbH must keep full books and file annual accounts. Many freelancers can use a simpler income-minus-costs statement. Keep invoices for eight years. Books and annual accounts must be kept for ten years, and business letters for six. Reliable bookkeeping from day one makes all of this easier. 

Electronic invoicing is the big change. Structured invoices have been required since January 2025. Issuing them is next. For larger firms, the transition rules end on 31 December 2026. From January 2027, German firms with prior-year turnover above €800,000 must issue structured invoices for domestic sales. Smaller firms follow in 2028. 

Invoices to UK customers are not domestic, so different rules may apply. Ask your adviser before you assume. 

What Are the Banking, Payroll and Insurance Requirements? 

Do UK Entrepreneurs Need a German Business Bank Account? 

In practice, a GmbH pays its share capital into a German business account. Banks ask for ID, proof of address, company papers and owner details. Start early. Most Germany business banking requirements are really identity checks.  

Sole traders can often use a personal account. Keep your UK account for UK income.  

Can You Continue Receiving Salary Through Your UK Company? 

Sometimes, but not simply. Paying for work done in Germany can bring German income tax and social security duties. Your UK PAYE position needs review too. Treat tax and social security separately.  

Health cover is compulsory. For 2026, the statutory general rate is 14.6%, plus an average extra 2.9%, according to Techniker Krankenkasse. Self-employed newcomers may have fewer choices, so check first.  

How Much Does Moving to Germany from the UK Cost in 2026? 

What Are the Main Relocation and Business Setup Costs? 

The cost of moving to Germany has several layers. Expect a permit fee, a rental deposit, removals, health insurance, business registration and accounting help. The permit costs up to €100.   

How Much Financial Preparation Should Business Owners Make? 

There is no universal budget, so create your own out of three buckets. The cost of living is first. Then comes business money, which for a GmbH should be at least €12,500. Ongoing compliance is third: accounting, taxes, and insurance. 

What Happens to Your UK Property, Pension and Investments? 

Will Germany Tax UK Rental Income and Investments? 

UK rent stays taxable in the UK, yet Germany may expect it on your return too. Treaty relief usually prevents double tax, but you must claim it. ISAs may lose their tax-free status in Germany. UK pensions need separate advice.   

Could Relocating Affect Business Shares or Future Exit Plans? 

Yes. A later sale can involve capital gains rules in both countries. The five-year UK rule can bite too. If an exit is on your radar, model it before you leave.  

Plan Your Move to Germany Without Putting Your UK Business at Risk 

Keeping your UK Ltd? Start with where decisions will be made and which UK duties continue. Setting up in Germany? Compare structures and costs before you sign anything. Freelancing? Confirm your permit route, registration and tax position first. Have staff, property or investments in both countries? You need joined-up advice. 

Whichever route you choose, plan before you leave. Some reliefs and risks turn on dates. 

At Lanop, we can review your UK business structure, accounting needs and tax position before you relocate. Take immigration and German legal questions to the German authorities or qualified German advisers. Book a pre-move review with Lanop, and bring your latest accounts, your expected move date, and your plan for taking income. 

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