Relocation abroad (Wegzug) of an IT entrepreneur

An entrepreneur from the IT sector planned to leave Germany for good and move his centre of life abroad. His assets consisted of several stakes in operating companies and other entrepreneurial structures and stood at around EUR 4.2 million at the planning stage. The planned relocation (Wegzug) was therefore at once a private decision and a tax-sensitive step with long-term consequences.

The central challenge lay in the complexity of the existing shareholdings. Design errors could have triggered tax burdens that would be almost impossible to correct later. At the same time, the question came up of how the relocation would affect the asset structure, possible inheritance cases (Erbfall) and long-term succession planning (Nachfolgeplanung).

I supported the entrepreneur through this process from end to end. On the German side I handled the tax structuring directly and brought in specialised experts from my network. In parallel we covered the inheritance-law angle and ran through the tax consequences of a possible inheritance case (Erbfall) in an international setting.

For the implementation abroad I brought in a tax adviser from my own network at the client's new place of residence. In this case the cooperation was with an adviser in Mallorca, so the structure could be coordinated seamlessly across borders.

In the end, individual stakes were restructured before the relocation in order to optimise the impact of exit taxation (Wegzugsbesteuerung — § 6 AStG, German exit tax for substantial shareholdings on relocation). Selected asset transfers (Vermögensübertragungen) within the family were carried out alongside. The structure was later reviewed by the German tax office in an audit and remained without objections.