What Brits in Germany need to know if they move back to the UK post-Brexit
Most people accept that moving to Germany is tricky and involves a lot of paperwork, but for Brits deciding to go back to the UK it's easy, right? After all, you're just going home? Wrong.
Moving countries is a time-consuming process - but if you're British and living in Germany you might think that moving back to the UK would be simpler? Well, there won't be a language barrier and as a UK citizen you won't need any immigration paperwork (although if you're bringing a German partner with then that gets complicated) - but you will still face administrative hurdles around pensions, healthcare, driving and taxes.
Some of these issues existed before Brexit, while others are as a direct result of the UK leaving the EU. Here are the most common questions from Brits thinking of moving back to the UK.
READ ALSO: Do Brits need to carry a residence permit at the UK border after Brexit?
Do I still qualify for NHS treatment?
You are entitled to NHS treatment if you are 'ordinarily resident' in the UK - there is no minimum time limit so as soon as you are back in the UK on a permanent basis, you can use the NHS. You will need to register for a GP in your local area in order to access non-emergency treatment, and to get an NHS number if you do not already have one.
You may need to provide proof of a UK address in order to use NHS services - although in reality UK citizens are rarely asked for this apart from when registering with a GP.
If you have been an S1 holder while living in the EU you should cancel that, just so there is no confusion over where you are getting your healthcare.
If you go back to Germany for a visit, remember that you are now a tourist and will need a GHIC card to get European healthcare, while travel insurance is also advised in case of accident or illness while visiting an EU country.
Can I drive on my EU licence in UK?
If you have been living in the EU you may have had to change your UK licence for a French or Spanish one for example.
Once you're back living in the UK you can continue to drive on you EU licence until the age 70 or if you move to the UK when you are 67 or over you can drive for three years. After this time you'll need to change your licence.
If your licence or photocard has an expiry date - once it's time to renew, you should swap it for a UK licence. You'll need a valid photocard licence to drive in the UK.
You can find details on the swap process for UK licences here, and if you're in Northern Ireland here.
UK residents with an EU licence can if they want exchange their licence for a UK one, if they wish to do so, without the need for a re-test.
Can I bring my German partner with me?
If you're returning alone you won't need to do any kind of immigration paperwork, your UK passport is enough. However if you are bringing with you a partner who is not a UK citizen, it becomes complicated.
After the end of the Brexit transition process there was an 'amnesty' period in which Brits with EU partners could move back to the UK under the old immigration rules. This is now ended and EU partners face the same immigration process as all other foreign spouses.
Essentially either your partner will need to have already secured a relatively high-paying job in the UK, or you will need to prove that you have a large amount of money to support them. They will need to go through the process of getting a UK visa (which is expensive - between £1,000 and £1,500 just for the visa fee) and there is no guarantee that their application will be successful simply because they are married/in a civil partnership with a Brit. They will also need to take an English-language exam.
Find full details here.
What about my pension contributions from the EU?
If you have been working in Germany, you will probably have been contributing to the German pension system. Pre-Brexit, UK and EU pension contributions could be blended into a single pension - but this is no longer the case.
Brits still living in the EU who are covered by the Withdrawal Agreement are theoretically covered by blended pensions if they had made pension contributions in the UK before moving to the EU, but the same does not apply if you move back to the UK.
The good news is that EU countries still practice this - so if for example you have worked in France, Germany and Italy your contributions will be totted up and paid out as a single pension - you apply in the last country you worked in. Bear in mind, however, that different countries have different pension ages.
The country that is paying your pension may require you to have an EU bank account to pay into - and you should check with the country paying your pension whether there are any other conditions to observe.
When it comes to a pension from the UK, it depends on how long you worked there - the basic rule is that you need 10 years of National Insurance contributions in order to get a state pension. However the UK government states that periods of work done in the EU or EEA 'may' count towards your qualifying period. Even if they do, however, they don't count towards the total pension amount - so for example if you worked for 7 years in the UK and the remaining 35 years of your career in the EU, you can qualify for a UK state pension, but it will only be based on the 7 years of work in the UK (in other words, the payment per month will be tiny).
Further details on UK pension entitlement here.
Do I need to hand back my residency card, health card etc before I leave the EU?
Most countries require that you hand back residency cards before you leave, but in truth this is rarely strictly enforced. Check with the immigration office that issued your Aufenthaltstitel (residency permit) about what you should do with them, but most of the Ausländerbehörde simply ask you to post it back.
If you do end up keeping residency or healthcare cards - don't use them on trips back to the EU. Tempting as it might be to avoid border queues or healthcare fees, you will create a confusing official record if you are claiming to be resident of two countries at once.
If you have taken German citizenship, that is a different matter and of course you are entitled to keep and use your German passport when visiting the EU.
READ ALL What do dual-nationals need to know about post-Brexit border controls
Do I still have to pay German taxes?
It's highly likely that you were paying taxes in the country you lived in. Generally, tax declarations concern the previous year, so you will have to do at least one tax declaration and payment after moving back to the UK.
In Germany, you usually need to pay taxes by the end of July (though the deadline's been pushed to October 2nd this year and September 2nd next year), and concerns the previous calendar year. So if for example you move back to the UK in October 2023, you will have to complete a tax declaration by September 2nd 2024, covering your 10 months of residency in Germany in 2023.
READ ALSO: What you need to know about Germany's extended tax filing deadlines
If you still own property in Germany you will pay property taxes there, and if you have any earnings in your former home you will likely still have to pay taxes there - check with your local tax office.
When you left the UK, you will likely have informed HMRC that you were leaving the country, so you will now have to tell them that you're back. Whether you have to fill out a UK self-assessment form depends on whether you are a salaried employee or self-employed/retired.
Can I keep my German bank account? Do I need a new UK account?
This one depends on the policy of your bank, but most banks in Germany require you to have a German address.
It's possible that your UK bank may have closed your account while you were living outside the UK, in which case you will need to open a new one.
A practical option while you are moving and still have interests in both countries is to open an internet bank account with a company like Wise or Revolut - these offer accounts in both pounds and euros and give you a European IBAN and a UK Sort code, so you can use it in both countries.
Will my EU qualifications be recognised?
If you were studying or gaining professional qualifications while living in the EU, don't assume that these will be recognised in the UK. Brexit ended the mutual recognition of qualifications - check with the professional or academic body that issued them whether these are recognised in the UK, you may need to acquire a certificate of recognition.
It's a good idea to check this point before you start job-hunting in the UK.
Be prepared for hassles
The advantage of moving back to the UK is that you're not starting from scratch and at least you know how things like council tax, electricity billing and healthcare work.
However, don't assume that it will all be plain sailing - if you don't have a recent UK address, you might be an anomaly in many companies' systems and you're likely to be forced to have several long and annoying conversations with call centres while you explain that while you are a UK citizen, you have not recently been living in the UK.
There are likely to be other niggles too - many UK car insurance companies won't recognise a no-claims bonus built up abroad, so you'll be back to paying full premiums on your car insurance, while banks might request extra money laundering checks due to your foreign associations.
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A lot of people in the UK also seem to be confused about the difference between citizenship and residency, so be prepared to have the following conversation a lot: "I've recently been living in Germany. No, I'm not German, I'm British, I was just living in Germany. Yes, I am a UK citizen."
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Moving countries is a time-consuming process - but if you're British and living in Germany you might think that moving back to the UK would be simpler? Well, there won't be a language barrier and as a UK citizen you won't need any immigration paperwork (although if you're bringing a German partner with then that gets complicated) - but you will still face administrative hurdles around pensions, healthcare, driving and taxes.
Some of these issues existed before Brexit, while others are as a direct result of the UK leaving the EU. Here are the most common questions from Brits thinking of moving back to the UK.
READ ALSO: Do Brits need to carry a residence permit at the UK border after Brexit?
Do I still qualify for NHS treatment?
You are entitled to NHS treatment if you are 'ordinarily resident' in the UK - there is no minimum time limit so as soon as you are back in the UK on a permanent basis, you can use the NHS. You will need to register for a GP in your local area in order to access non-emergency treatment, and to get an NHS number if you do not already have one.
You may need to provide proof of a UK address in order to use NHS services - although in reality UK citizens are rarely asked for this apart from when registering with a GP.
If you have been an S1 holder while living in the EU you should cancel that, just so there is no confusion over where you are getting your healthcare.
If you go back to Germany for a visit, remember that you are now a tourist and will need a GHIC card to get European healthcare, while travel insurance is also advised in case of accident or illness while visiting an EU country.
Can I drive on my EU licence in UK?
If you have been living in the EU you may have had to change your UK licence for a French or Spanish one for example.
Once you're back living in the UK you can continue to drive on you EU licence until the age 70 or if you move to the UK when you are 67 or over you can drive for three years. After this time you'll need to change your licence.
If your licence or photocard has an expiry date - once it's time to renew, you should swap it for a UK licence. You'll need a valid photocard licence to drive in the UK.
You can find details on the swap process for UK licences here, and if you're in Northern Ireland here.
UK residents with an EU licence can if they want exchange their licence for a UK one, if they wish to do so, without the need for a re-test.
Can I bring my German partner with me?
If you're returning alone you won't need to do any kind of immigration paperwork, your UK passport is enough. However if you are bringing with you a partner who is not a UK citizen, it becomes complicated.
After the end of the Brexit transition process there was an 'amnesty' period in which Brits with EU partners could move back to the UK under the old immigration rules. This is now ended and EU partners face the same immigration process as all other foreign spouses.
Essentially either your partner will need to have already secured a relatively high-paying job in the UK, or you will need to prove that you have a large amount of money to support them. They will need to go through the process of getting a UK visa (which is expensive - between £1,000 and £1,500 just for the visa fee) and there is no guarantee that their application will be successful simply because they are married/in a civil partnership with a Brit. They will also need to take an English-language exam.
Find full details here.
What about my pension contributions from the EU?
If you have been working in Germany, you will probably have been contributing to the German pension system. Pre-Brexit, UK and EU pension contributions could be blended into a single pension - but this is no longer the case.
Brits still living in the EU who are covered by the Withdrawal Agreement are theoretically covered by blended pensions if they had made pension contributions in the UK before moving to the EU, but the same does not apply if you move back to the UK.
The good news is that EU countries still practice this - so if for example you have worked in France, Germany and Italy your contributions will be totted up and paid out as a single pension - you apply in the last country you worked in. Bear in mind, however, that different countries have different pension ages.
The country that is paying your pension may require you to have an EU bank account to pay into - and you should check with the country paying your pension whether there are any other conditions to observe.
When it comes to a pension from the UK, it depends on how long you worked there - the basic rule is that you need 10 years of National Insurance contributions in order to get a state pension. However the UK government states that periods of work done in the EU or EEA 'may' count towards your qualifying period. Even if they do, however, they don't count towards the total pension amount - so for example if you worked for 7 years in the UK and the remaining 35 years of your career in the EU, you can qualify for a UK state pension, but it will only be based on the 7 years of work in the UK (in other words, the payment per month will be tiny).
Further details on UK pension entitlement here.
Do I need to hand back my residency card, health card etc before I leave the EU?
Most countries require that you hand back residency cards before you leave, but in truth this is rarely strictly enforced. Check with the immigration office that issued your Aufenthaltstitel (residency permit) about what you should do with them, but most of the Ausländerbehörde simply ask you to post it back.
If you do end up keeping residency or healthcare cards - don't use them on trips back to the EU. Tempting as it might be to avoid border queues or healthcare fees, you will create a confusing official record if you are claiming to be resident of two countries at once.
If you have taken German citizenship, that is a different matter and of course you are entitled to keep and use your German passport when visiting the EU.
READ ALL What do dual-nationals need to know about post-Brexit border controls
Do I still have to pay German taxes?
It's highly likely that you were paying taxes in the country you lived in. Generally, tax declarations concern the previous year, so you will have to do at least one tax declaration and payment after moving back to the UK.
In Germany, you usually need to pay taxes by the end of July (though the deadline's been pushed to October 2nd this year and September 2nd next year), and concerns the previous calendar year. So if for example you move back to the UK in October 2023, you will have to complete a tax declaration by September 2nd 2024, covering your 10 months of residency in Germany in 2023.
READ ALSO: What you need to know about Germany's extended tax filing deadlines
If you still own property in Germany you will pay property taxes there, and if you have any earnings in your former home you will likely still have to pay taxes there - check with your local tax office.
When you left the UK, you will likely have informed HMRC that you were leaving the country, so you will now have to tell them that you're back. Whether you have to fill out a UK self-assessment form depends on whether you are a salaried employee or self-employed/retired.
Can I keep my German bank account? Do I need a new UK account?
This one depends on the policy of your bank, but most banks in Germany require you to have a German address.
It's possible that your UK bank may have closed your account while you were living outside the UK, in which case you will need to open a new one.
A practical option while you are moving and still have interests in both countries is to open an internet bank account with a company like Wise or Revolut - these offer accounts in both pounds and euros and give you a European IBAN and a UK Sort code, so you can use it in both countries.
Will my EU qualifications be recognised?
If you were studying or gaining professional qualifications while living in the EU, don't assume that these will be recognised in the UK. Brexit ended the mutual recognition of qualifications - check with the professional or academic body that issued them whether these are recognised in the UK, you may need to acquire a certificate of recognition.
It's a good idea to check this point before you start job-hunting in the UK.
Be prepared for hassles
The advantage of moving back to the UK is that you're not starting from scratch and at least you know how things like council tax, electricity billing and healthcare work.
However, don't assume that it will all be plain sailing - if you don't have a recent UK address, you might be an anomaly in many companies' systems and you're likely to be forced to have several long and annoying conversations with call centres while you explain that while you are a UK citizen, you have not recently been living in the UK.
There are likely to be other niggles too - many UK car insurance companies won't recognise a no-claims bonus built up abroad, so you'll be back to paying full premiums on your car insurance, while banks might request extra money laundering checks due to your foreign associations.
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A lot of people in the UK also seem to be confused about the difference between citizenship and residency, so be prepared to have the following conversation a lot: "I've recently been living in Germany. No, I'm not German, I'm British, I was just living in Germany. Yes, I am a UK citizen."
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