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German statutory pensions are not always fully taxable in the Netherlands

2. July 2026

 

Ruling by the Hoge Raad 

On 19 June 2026, the Hoge Raad (the Dutch Supreme Court) clarified the taxation of German old-age pensions in the Netherlands – in particular, regarding pensions with a gross annual amount of less than 15,000 euros. The ruling primarily affects pensioners living in the Netherlands who receive a pension from the German Pension Insurance (Deutsche Rentenversicherung, DRV). 

Which pensioners is this ruling relevant to? 

The ruling clarifies that smaller German old-age pensions may not automatically be taxed in full in the Netherlands. It is also important to consider the extent to which the contributions were tax-deductible for the purposes of building up the pension. For recipients of a German statutory pension, it may therefore be worthwhile to check what proportion of the contributions paid at the time was tax-deductible. This percentage may influence which part of the pension payments is taxable in the Netherlands. 

Outlook 

It is not yet known how the Dutch tax authority (Belastingdienst) will implement this ruling in practice. The Belastingdienst is currently still reviewing the Supreme Court’s ruling and its implications. As soon as further information becomes available, the Cross-Border Information Point (GrenzInfoPunkt) will report on this further. 

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