UK pension taxation in Germany under the DTA 2010. State Pension Article 17(2) rules, private pension tax rates up to 45%, PCLS treatment, and strategic planning explained.

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When a footballer signs an overseas contract, the emotional centre of the decision is often the family home. The house is where the kids grew up, where the partner's family is nearby, where the life the player built in the UK physically lives. Selling it feels like closing a door that might need reopening.
That emotional weight is exactly why so many overseas moves go wrong tax-wise. The UK home is the single most common trigger under the Statutory Residence Test that keeps a footballer UK tax resident after they have physically left. Keeping it available, occupied by family on an informal basis, or used by you during breaks can each pull you back into the UK tax net, costing six figures a year in avoidable tax.
This piece walks through the three options (sell, let, keep available), how each affects your tax position, and the specific framework that footballers use to make the right decision before the plane takes off. If you are moving abroad in the next 12 months, this is the call that shapes the tax outcome more than any other.
Selling the UK home before you leave is the cleanest SRT position. No accommodation tie, no UK home automatic test, no ambiguity about availability or family occupation. If the sale is timed correctly, the tax consequences are usually manageable.
For a permanent or long-contract overseas move, selling is usually the right answer. For short contracts with a likely return, the reversibility cost is real, and the other options may make more sense.
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Letting the property to a third party on a proper tenancy removes the accommodation tie (provided the property is genuinely not available to you during the tenancy), but it creates a set of new obligations.
Letting works well for medium-length overseas contracts (two to five years) where a return is likely and selling would be wasteful. The NRLS mechanics are routine for a good accountant to handle; the SRT benefit is real as long as the property is genuinely let.
Keeping the home empty and ready for you to walk back into whenever is the most expensive option SRT-wise, and usually the one footballers default to without realising.
This is often the emotional favourite and the financial worst choice. Unless the overseas contract is genuinely short (under two years) and the return is certain, keeping the home available usually costs more in lost tax benefit than the flexibility is worth.
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Principal Private Residence (PPR) relief is what protects most footballers from CGT on the sale of their main home. The relief is automatic for any period the property was your only or main residence during your ownership.
Key points for a footballer selling before departure:
For most footballers, PPR covers the whole gain on the main family home. Complications usually come from second homes, investment properties, or periods where the property was let before departure. This is where Principal Private Residence relief interacts with pre-departure letting to shape the CGT outcome, and where running the numbers before exchange of contracts protects against surprises.
If you let the UK home while non-resident, the NRLS applies. In practice, this means:
The scheme is designed to be routine, not punitive. A good accountant handles the mechanics in a few hours a year. What matters is that you register with HMRC before the first rent is paid, and that your letting agent is NRLS-aware.
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A common footballer scenario is leaving the family home occupied by the partner, parents, or siblings while you move abroad. This sits in an SRT grey zone that HMRC has become increasingly strict about.
The key question is whether the accommodation is genuinely not available to you. If your partner lives in the house and you can stay there whenever you visit the UK, the accommodation tie applies. If the property is formally let to a family member on a proper tenancy at market rent, the accommodation tie can be removed, but only if the documentation holds up.
Practical points:
The right option depends on how long you will be away and how certain the return is:
The one option that almost never works cleanly is keeping the home available and used informally by family while claiming non-residence. That combination is the most common source of SRT challenges from HMRC.
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Take a 27-year-old Premier League midfielder signing a three-year contract in Saudi Arabia. The family home is a £2.5m detached house in Cheshire, owned outright, and has been the main residence for five years. Partner and two young children will stay in the UK while the kids finish the school year, then join in the summer.
Running the three options:
For this player, option two is almost always the right answer. The family logistics can be bridged by a short-term UK rental until the school year ends, and the formal tenancy starts once the family joins overseas. The tax position stays clean, the asset stays in the portfolio, and the return is easy.
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Planning the UK home decision looks like this:
The aim is not to pick the cheapest option in the moment. It is to pick the one that fits the overall tax position of the move. For most players, the fastest way to take this from a household debate to a specific number is a short, informal conversation with someone who has worked on the property side of dozens of football moves.
If you are reading this and thinking:
Then the next step is a structured conversation focused on clarity, not implementation. Not because anything is urgent, but because the UK home decision is almost always the highest-leverage tax decision in an overseas move, and it is much cheaper to get right before the move than after.
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The UK home decision is not really about:
It is about:
Most footballers handle the UK home decision emotionally and discover the tax cost on the first post-departure return. The ones who get it right almost always ran the numbers on all three options before making the call. This is where the UK property decision shapes SRT residency and the real tax cost of an overseas move, and where a short planning conversation before departure saves more tax than almost anything else.
For most footballers, Principal Private Residence relief covers the gain on the main home in full, leaving no CGT to pay. Complications arise if the property was let before sale, if it was not your main residence throughout ownership, or if it is a second home. Running the numbers before exchange is the right step.
It is very difficult. A partner remaining in the home usually creates both the family tie and the accommodation tie under the SRT. That does not automatically make you UK resident, but it significantly reduces your allowed UK days before residency kicks in.
If the tenancy is formal, at market rent, and the property is genuinely not available to you, the accommodation tie can be removed. If the arrangement is informal or below market rent, HMRC will usually treat the property as still available to you.
Yes, if you let a UK property while non-resident. Without registration, your letting agent or tenant is required to deduct basic-rate tax at source. Registering and applying for gross-rent approval simplifies cash flow and compliance.
It is an automatic UK residency test that applies if you have a UK home available for 91 consecutive days and use it for 30 days during the tax year, while having no equivalent overseas home used on more than 30 days. Meeting this test makes you UK resident for the whole tax year.
Having an equivalent overseas home you use on more than 30 days a year helps defend against the UK home automatic test. For a multi-year overseas move, establishing a genuine overseas home is usually part of the structural plan.
Jamie is an experienced Private Wealth Adviser at Skybound Wealth, specialising in working with professional athletes, content creators, and business owners. With over 15 years spent in elite sport, he brings the same discipline, resilience, and clarity of vision that defined his career on the pitch into his work with clients today.
This article is for information purposes only and does not constitute financial advice. Financial planning outcomes depend on individual circumstances, residency, tax status, and objectives. Professional advice should always be sought before making financial decisions.
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