Exit taxation (Germany)
Wegzugsbesteuerung
Other languages: Deutsch · Français · Español
German taxation of unrealised gains on shares in corporations, from a holding of 1 percent, when a person moves their residence abroad (section 6 AStG).
Since 2022, the tax can be paid in seven annual instalments on application; the former interest-free deferral for moves to other EU states no longer applies.
In practice
Exit taxation often takes entrepreneurial families by surprise, because a holding of one percent in a corporation is enough and no sale takes place. In practice, a move abroad should be planned early: valuation of the shares, payment in instalments and the rules for returning to Germany. A child who has inherited or received shares as a gift can also trigger the tax by moving abroad.
Distinctions and common mistakes
The tax is due although nothing is sold, so the liquidity has to come from elsewhere. A common mistake is to overlook that a gift or inheritance of shares to a person who is not resident in Germany can trigger the same taxation.
Relevant in: Germany
Related terms
- Tax residence
- The country in which a person is subject to unlimited tax liability because of residence, stay or other criteria.
Mentioned in these guides
- Relocating a wealthy family: a checklist for Switzerland, Germany and AustriaWhat wealthy families must consider when moving between Switzerland, Germany and Austria: tax residence, exit tax, succession law, banks, KYC and AEOI.