{"id":4178,"date":"2026-01-29T13:32:54","date_gmt":"2026-01-29T12:32:54","guid":{"rendered":"https:\/\/mavaro-tax.com\/goodbye-germany-focus-on-exit-taxation\/"},"modified":"2026-01-29T13:34:30","modified_gmt":"2026-01-29T12:34:30","slug":"goodbye-germany-focus-on-exit-taxation","status":"publish","type":"post","link":"https:\/\/mavaro-tax.com\/en\/goodbye-germany-focus-on-exit-taxation\/","title":{"rendered":"Goodbye Germany – Focus on exit taxation"},"content":{"rendered":"\t\t
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Goodbye Germany - Focus on exit taxation<\/h1>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Many entrepreneurs seek their (tax) fortune abroad and why not, when the prospects are brighter abroad. For shareholders of corporations, however, moving abroad often means paying high taxes in Germany. <\/p>

The reason for this is the so-called exit taxation (Section 6 of the Foreign Tax Act). This provision has existed in German tax law since 1972 and will be significantly tightened from January 1, 2022. <\/p>

Essentially, the German legislator wants to tax the assets created in Germany before the move. This is because this is generally no longer possible after moving away. <\/p>

Despite new regulations from 2022, the basic concept of exit taxation remains fundamentally unchanged. The following article mainly refers to the new regulations. <\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/section>\n\t\t\t\t

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What is exit taxation?<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Anyone who has been subject to unlimited tax liability in Germany for at least 7 of the last 12 years and holds shares in a German or foreign corporation as private assets is subject to the so-called German exit tax when moving away. Provided the shareholder meets the minimum shareholding requirement of 1% within the last five years prior to departure. This is also referred to as shares within the meaning of Section 17 of the Income Tax Act. <\/p>

If exit taxation is applied, a sale of the investment is deemed to have taken place at the time of exit. A “notional capital gain” is therefore taxed. Taxation therefore takes place without an inflow of liquidity. <\/p>

Note: The term “exit tax” is used in everyday language, but in legal terms this is income tax.<\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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Moving away - what does that mean?<\/h2>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Moving away generally means giving up your German place of residence. The following cases are covered by the law: <\/p>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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