German exit tax (Wegzugsteuer) taxes unrealised gains on company shareholdings when you leave Germany, as if you had sold them. It applies if you held at least 1% of a company within the last five years and were fully taxable in Germany for at least seven of the last 12 years. Since 2025, large fund holdings can also be affected.
Es hängt ab von
Company stakes of at least 1% and fund holdings of at least 1% of a fund or €500,000 in acquisition costs per fund are in scope.
The rule applies only if you were fully taxable in Germany for at least seven of the last 12 years.
A return within seven years, extendable by up to five years, can cancel the tax if the conditions are met.
Wer es braucht
Founders, shareholders of a GmbH or UG, employees with significant equity, family business owners and investors with large fund portfolios should check exit tax before they move. It can also be triggered without a move, for example when shares are gifted or inherited to someone outside Germany, or when Germany loses its taxing right. Because the tax is due on a gain you have not received in cash, it can create a liquidity problem. Planning should start well before departure and involve a tax adviser.
Wie es funktioniert
- 1
Check the conditions
Exit tax applies if you held at least 1% of a corporation at any time within the last five years and were fully taxable in Germany for at least seven of the last 12 years.
- 2
Check fund holdings
Since 1 January 2025, units in an investment fund are covered if you hold at least 1% of the fund or acquisition costs of at least €500,000 in that fund.
- 3
Value the holdings
The gain is calculated as if you had sold the shares at fair market value on departure. A valuation is often needed for unlisted companies.
- 4
Decide how to pay
On application, the tax can be paid in seven equal annual instalments without interest, generally only against security.
- 5
Plan a possible return
If you become fully taxable in Germany again within seven years, the tax can lapse; the tax office may extend this by up to five years if you still intend to return.
Was es kostet
| Posten | Betrag | Hinweis |
|---|---|---|
| Exit tax on the deemed gain | [amount] | Calculated like income tax on a sale; amount depends on the gain and your personal situation. |
| Security for instalment payments | [amount] | Usually required, for example a bank guarantee; the shares themselves are often not accepted. |
| Valuation and tax advice | [amount] | Fees depend on the complexity of the holdings. |
Wichtige Fakten
| Fakt | Wert | Quelle | Geprüft |
|---|---|---|---|
| Events triggering exit tax (§ 6(1) AStG) | Giving up German residence or habitual abode; gift or inheritance of shares to a non-resident; exclusion or restriction of Germany's taxing right | 1 | geprüft 15 October 2026 |
| Exit tax: shareholding threshold (§ 17 EStG) | At least 1% of a corporation at any time within the last five years | 342 | geprüft 15 October 2026 |
| Exit tax: prior unlimited tax liability (§ 6(2) AStG) | At least seven years within the last 12 years | 134 | geprüft 15 October 2026 |
| Current version of § 6 AStG applies from | Assessment year 2022 (moves from 1 January 2022) | 13 | geprüft 15 October 2026 |
| Exit tax payment by instalments (§ 6(4) AStG) | On application, seven equal annual instalments, interest-free, generally only against security | 143 | geprüft 15 October 2026 |
| Exit tax lapses on return (§ 6(3) AStG) | If unlimited German tax liability resumes within seven years; tax office can extend by up to five years if the intention to return continues | 134 | geprüft 15 October 2026 |
| Return relief lost through profit distributions | If distributions during the absence exceed 25% of the shares' value | 41 | geprüft 15 October 2026 |
| Exit tax on investment fund units (§ 19(3) InvStG, Jahressteuergesetz 2024) | Applies from 1 January 2025 if you hold at least 1% of a fund or acquisition costs of at least €500,000 per fund | 52 | geprüft 15 October 2026 |
Häufige Fehler
- Assuming that moving within the EU still means unlimited interest-free deferral, which ended with the 2022 reform.
- Overlooking indirect holdings and holdings that fell below 1% only recently, because the five-year look-back still counts.
- Forgetting that large fund portfolios have been in scope since 2025.
- Taking large dividends during a planned temporary absence, which can remove the return relief if distributions exceed 25% of the value.
- Starting the planning after deregistration, when options are already limited.
FAQ
Does exit tax apply to my ETF savings plan?
Only above certain thresholds. Since 1 January 2025, fund units are covered if you hold at least 1% of a fund or your acquisition costs in that fund reach €500,000. The thresholds apply per fund. Special investment funds have no threshold. Most ordinary savers stay below these limits, but larger portfolios should be checked.
Can I spread the payment?
Yes, on application. The tax can be paid in seven equal annual instalments without interest, but the tax office generally grants this only against security. Instalments may become due early in certain situations, such as a sale of the shares, so get advice on the conditions in your case.
What if I come back to Germany?
If you become fully taxable in Germany again within seven years, the tax claim can lapse, provided the shares were not sold or transferred in the meantime and distributions did not exceed 25% of their value. The tax office can extend the period by up to five years if your intention to return continues.
Is exit tax going to be abolished?
There is no change in force. An opposition motion tabled in the Bundestag asked for § 6 AStG to be repealed, but a motion is not a law and does not change your obligations. Plan on the basis of the current rules, and check for official changes shortly before you move.
Quellen
- Deutscher Bundestag, Drucksache 19/28652 – Gesetzentwurf der Bundesregierung, ATAD-Umsetzungsgesetz (new § 6 AStG) (öffnet sich in einem neuen Tab)Authority · geprüft 15 October 2026
- Deutscher Bundestag, Drucksache 21/2544 – Antrag: Aufhebung der sogenannten Wegzugsbesteuerung gemäß § 6 AStG (4 November 2025) (öffnet sich in einem neuen Tab)Authority · geprüft 15 October 2026
- EY Deutschland, Auslandseinsatz und Wegzugsbesteuerung (öffnet sich in einem neuen Tab)Official guidance · geprüft 15 October 2026
- PwC Deutschland, Steuer Shorts: Wegzugsbesteuerung, § 6 AStG (öffnet sich in einem neuen Tab)Official guidance · geprüft 15 October 2026
- Forvis Mazars Deutschland, Wegzugsbesteuerung bei Fondsanteilen: neue Regeln seit 2025 (öffnet sich in einem neuen Tab)Official guidance · geprüft 15 October 2026
Über den Autor
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Über den Prüfer
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