Quick answer — leaving Austria with a GmbH. When you move abroad and Austria loses its right to tax gains on your GmbH shares, Austria taxes the unrealised gain as if you had sold them (Wegzugsbesteuerung), at the special 27.5% rate. For moves within the EU or EEA, you can usually spread the payment over five years. Your GmbH stays fully taxable in Austria at 23% corporate tax as long as its seat or place of management is there.
Executive Summary & Context
Austrian founders and consultants often run their business through a GmbH, especially since the minimum share capital was cut to €10,000 in 2024. When the owner leaves Austria, two things happen. Austria taxes the hidden gain in the shares on departure, and the GmbH carries on as an Austrian company, paying Austrian corporate tax and withholding tax on dividends.
Austria's exit tax is less dramatic than Germany's for small companies, because it is calculated on the gain since you acquired the shares and can be paid in instalments for EU moves. But it applies to shareholdings of any size, and a valuable company can produce a significant bill.
Who this guide is for
- GmbH founders, freelancers and consultants leaving Austria to become location-independent or settle abroad.
- Owners of growing Austrian startups with significant unrealised value.
Who it is not for
This guide does not cover owners staying in Austria, employees on a foreign assignment, cross-border commuters, or settled expats. For your personal move, see our relocation guides.
For other countries and the general framework, see our overview on relocating your business abroad.
Legal Entities & Comparison Matrix
| Option | What happens | Tax consequences | Works best when |
|---|
| Keep the GmbH | It stays Austrian; you remain Geschäftsführer from abroad or appoint an Austrian managing director | Exit tax on your shares; Austrian corporate tax continues; 27.5% withholding on dividends, reduced by treaty | Austrian clients, staff or significant value |
| Liquidate the GmbH | Dissolution and liquidation | Liquidation proceeds taxed at 27.5% | The business is personal and can restart abroad |
| Sell the shares | Sale before departure | Capital gain taxed at 27.5% | There is a buyer |
| Restructure | Move the business to a foreign company or transfer assets | Corporate exit taxation of hidden reserves | You will run the business from abroad long term |
Key Austrian rates
| Tax | Rate |
|---|
| Corporate income tax (KöSt) | 23% |
| Tax on dividends and capital gains on shares (KESt / special rate) | 27.5% |
| GmbH minimum share capital | €10,000 |
Also relevant: the German Wegzugsbesteuerung on GmbH shares and the Belgian SRL after you move abroad.
Substance, Residence & Compliance Governance
Austria's exit tax
Austrian law treats the loss of Austria's taxing right over your shares as a deemed sale. The unrealised gain — market value minus acquisition cost — is taxed at the special 27.5% rate.
- Moves within the EU or EEA (with comprehensive administrative and recovery assistance): you can usually apply to spread the tax in equal instalments over five years.
- Moves to other countries: the tax is generally due immediately.
- Selling the shares or moving them out during the instalment period can make the remaining balance payable.
Where your GmbH is taxed after you leave
A GmbH is fully taxable in Austria if its registered seat or place of management is in Austria. If you manage it from your new country, that country may claim it is resident there or has a permanent establishment there; the tax treaty decides.
Paying yourself as a non-resident
- Dividends face 27.5% Austrian withholding tax, reduced to the treaty rate at source or by refund.
- Managing director's salary is generally taxable where the work is done, but treaties differ for directors; social insurance depends on EU coordination rules or bilateral agreements.
Administration
Deregister your residence (Abmeldung), declare the exit tax with your departure-year return and apply for instalments if eligible, and keep the GmbH's accounting, annual accounts and filings in Austria up to date.
Setup Costs & Economic Model
| Cost item | Indicative amount (2026) | Notes |
|---|
| Share valuation for the exit tax | €1,500–8,000 | Needed for the deemed sale |
| Tax adviser for the departure-year return and instalment application | €1,000–4,000 | |
| Ongoing GmbH accounting and returns | €2,500–7,000 a year | Unchanged after you leave |
| Austrian managing director (optional) | Depends on scope | Helps keep management in Austria |
| Liquidation (if closing) | €2,000–5,000 | Notary, liquidator, final accounts |
Amounts are indicative.
The economic model: a GmbH worth €250,000
| Step | Amount |
|---|
| Market value of the shares on departure | €250,000 |
| Acquisition cost | €10,000 |
| Gain | €240,000 |
| Exit tax at 27.5% | €66,000 |
| Annual instalment over five years (EU/EEA move) | €13,200 |
For a move outside the EU or EEA, the whole €66,000 would generally be due straight away. Choosing the destination and the departure date are therefore part of the tax planning.
Step-by-Step Formation & Business Banking
- Value your GmbH shares as of the planned departure date.
- Check whether your destination allows instalments: EU/EEA countries with assistance arrangements versus others.
- Compare keep, liquidate, sell and restructure, including future Austrian corporate tax versus a company in your new country.
- Plan distributions before and after departure.
- Read the tax treaty with your new country for company residence, dividends and director's pay.
- Decide where the GmbH will be managed, and appoint an Austrian managing director if you want management to stay in Austria.
- Deregister your residence and file your departure-year return with the exit tax and instalment application.
- Update the commercial register and your bank with your new address and tax residence.
- Register in your new country and obtain a tax residency certificate.
Business banking after you leave
Austrian banks generally keep the GmbH's account but will update KYC and may ask where the company is managed. Check online banking and identification options for non-resident directors before you leave.
The Austria Founder Exit Guide sets out the full timeline and filings — get it when you plan your GmbH's exit with Heavnn.
Frequently Asked Questions (FAQ)
Does Austria have an exit tax on company shares?
Yes. When you move abroad and Austria loses its taxing right over your shares, it taxes the unrealised gain at the special 27.5% rate, as if you had sold them.
Can I pay the Austrian exit tax in instalments?
For moves to EU or EEA countries with comprehensive administrative and recovery assistance, you can usually apply to pay in equal instalments over five years. For other destinations, the tax is generally due immediately.
Does my GmbH stay Austrian if I move abroad?
Yes, as long as its registered seat or place of management stays in Austria. Your new country may also claim it if you manage it from there.
How are dividends from my Austrian GmbH taxed after I leave?
Austria withholds 27.5% on dividends, reduced to the treaty rate at source or by refund. Your new country then taxes them under its rules.
What is the minimum capital of an Austrian GmbH?
Since 2024, the minimum share capital of a GmbH is €10,000.
Plan Your GmbH's Exit with Heavnn
Where you move and when you move both change Austria's exit tax. Heavnn models both before you deregister.
- Get the Austria Founder Exit Guide for the timeline and filings.
- Then see what leaving will cost you — and whether keeping, closing or restructuring your GmbH works best.
Plan your company's exit with Heavnn →
This guide is general information, not tax or legal advice. Rules are summarised as of October 2026.
