Ruling by the Hoge Raad 

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

Which pensioners is this ruling relevant to? 

In the court’s view, smaller German old-age pensions may not be taxed in full in the Netherlands on a flat-rate basis. Rather, the decisive factor is the extent to which the contributions were tax-deductible during the period of employment. It may therefore be important for recipients of a German statutory pension to check the tax-deductible portion of the contributions they paid in the past, as this may affect the taxation of their pension payments in the Netherlands.

Important

It is not yet clear exactly how the ruling will be implemented in practice. The Dutch tax authority (Belastingdienst) is currently reviewing the decision and its implications. At this stage, there are neither binding guidelines on its application nor specific procedural rules.

The GrenzInfoPunkte also do not currently have any further information on how the authorities will handle this in practice and are therefore unable to provide advice on implementation at this stage. As soon as reliable information becomes available, the GrenzInfoPunkte will provide an update.

This article was updated on 3 July 2026 following corrections.