Who should review exit tax
Individuals with qualifying shareholdings and sufficient German tax history are the core group. Reorganisations, gifts and moves to or from trust structures can add complexity.
The liquidity problem
The taxable gain is based on value at departure, but cash may not exist. Deferral or instalment rules can help in qualifying cases, usually with conditions and ongoing duties.
- Current company valuation.
- Acquisition cost and transaction history.
- Planned country and move date.
- Ownership through direct and indirect structures.
Plan before residence changes
Valuation, restructuring and treaty questions should be resolved before the move. Actions taken after tax residence has ended may come too late or create additional taxes.
Frequently asked
Does exit tax apply to every expat leaving Germany?
No. It targets defined ownership and residence situations, especially substantial company shareholdings.
Is an actual sale required?
No. The rule can tax a deemed disposal.
Can payment be deferred?
Instalment or deferral mechanisms may be available under current law, subject to conditions and compliance.
This guide is general information on German tax law, not advice on your individual case. Rules and figures change with each tax year.