Quick answer — leaving Germany with a GmbH. If you have held at least 1% of a company within the last five years and were fully taxable in Germany for at least 7 of the last 12 years, moving abroad triggers Wegzugsbesteuerung (§ 6 AStG): Germany taxes the unrealised gain on your GmbH shares as if you had sold them. The tax can usually be paid in seven interest-free annual instalments. Your GmbH stays fully taxable in Germany because its registered seat is there.
Germany has one of the strictest exit regimes in Europe for founders. A GmbH owner who moves abroad can face a tax bill on the value of their shares on departure day, even though nothing was sold and no cash came in. Since the 2022 reform, the old indefinite deferral for moves within the EU has gone, replaced by instalments.
At the same time, the GmbH itself does not move. It keeps its registered seat in Germany and remains subject to German corporate tax, solidarity surcharge and trade tax on its German profits — about 30% in total in many cities. Your new country may also claim part of its profits if you run it from there. And if you move to a low-tax country, Germany can keep taxing some of your German-source income for up to ten years.
This guide is not for owners staying in Germany, for employees taking a job abroad, or for settled expats. For the personal side of your move, see our relocation guides.
Comparing countries? See our overview on relocating your business abroad.
Germany's neighbours have similar rules: compare the Austrian exit tax on GmbH shares and the Dutch emigration tax on a BV.
The German exit tax applies when you end your unlimited tax liability in Germany, typically by giving up your German residence and habitual abode, if:
It also applies in some situations without moving, such as gifting shares to a non-resident. The gain is the difference between the market value of the shares on departure and their acquisition cost. It is taxed under the partial-income method: 60% of the gain is added to your income and taxed at your personal rate.
Instalments instead of deferral: since 2022, the tax is due on departure but can be paid in seven equal, interest-free annual instalments, usually against security. Selling the shares or receiving large distributions during that time makes the outstanding balance payable.
Returning to Germany: if you leave only temporarily and become fully taxable in Germany again within the statutory period, the exit tax can be cancelled, provided the conditions are met.
A GmbH is fully taxable in Germany if either its registered seat or its place of management is in Germany. Moving abroad yourself does not change the GmbH's seat, so it stays fully taxable in Germany. If you manage it from your new country, that country may also consider it resident there, or treat your home office as a permanent establishment. The tax treaty then decides, and some treaties leave it to the two tax authorities to agree.
If you are a German citizen, move to a low-tax country and keep substantial economic interests in Germany, extended limited tax liability (§ 2 AStG) can keep some German-source income taxable in Germany for up to ten years after you leave. This matters especially for moves to the UAE or similar jurisdictions.
Deregister your residence (Abmeldung), inform the tax office, file the exit tax declaration with your final full-year return, and keep the GmbH's filings, bookkeeping and annual accounts up to date in Germany.
Amounts are indicative.
This is a simplified example; your actual rate depends on your other income in the departure year. For many founders, the exit tax is the single largest cost of leaving, which is why the valuation and timing deserve careful planning.
Start at least six to twelve months before you plan to deregister.
German banks usually keep the GmbH's account but will update the managing director's details and may ask where the company is managed. Some banks restrict online banking or identification for non-residents, so confirm before you leave.
The Germany Founder Exit Guide sets out the full timeline and documents for leaving with a GmbH — get it when you plan your GmbH's exit with Heavnn.
It is Germany's exit tax under § 6 AStG. When you stop being fully taxable in Germany, it taxes the unrealised gain on shares of at least 1% in a company as if you had sold them, provided you were fully taxable in Germany for at least 7 of the last 12 years.
Not indefinitely any more. Since 2022, it can be paid in seven equal, interest-free annual instalments, usually against security. Selling the shares during that period makes the remaining balance due.
Yes. A GmbH with its registered seat in Germany stays fully taxable there. If you manage it from your new country, that country may also claim it, and the tax treaty decides.
If you leave only temporarily and become fully taxable in Germany again within the statutory period, the exit tax can be cancelled, as long as the shares have not been sold in the meantime.
Under § 2 AStG, German citizens who move to a low-tax country while keeping substantial economic interests in Germany can remain taxable on some German-source income for up to ten years.
The exit tax is set on departure day. Heavnn models the valuation, timing and options before you deregister.
Plan your company's exit with Heavnn →
This guide is general information, not tax or legal advice. Rules are summarised as of October 2026.
