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Home / Tolley's Global Mobility: Employment Taxes (Europe) /Germany /6. Globally mobile employees / 6.5 Non-residents with income from the jurisdiction
Commentary

6.5 Non-residents with income from the jurisdiction

Germany

Tax residents of Germany are subject to tax on their worldwide income subject to the provisions of a double tax treaty. This is referred to domestically as 'unlimited tax liability'.

Non-residents are subject to tax only on their domestic German income. This is referred to as being subject to 'limited tax liability'.

Additionally, individuals in receipt of certain types of domestic German income are also subject to limited tax liability (EStG, s 49). The income is that arising from:

  1. Ìý

    •ÌýÌýÌýÌý sporting activities

  2. Ìý

    •ÌýÌýÌýÌý artistic work

  3. Ìý

    •ÌýÌýÌýÌý entertaining or similar performances

  4. Ìý

    •ÌýÌýÌýÌý other services related to the services above

An authorised signatory or member of the board of a company with management in Germany is also subject to limited tax liability.

Persons with limited tax liability may only deduct expenses

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Web page updated on 17 Mar 2025 15:26