Cross-Border
Wegzugsteuer (exit tax) — 2022 reform, level, planned avoidance
The Wegzugsteuer under § 6 AStG hits everyone who is unlimitedly tax-liable in Germany and holds at least 1 percent in a Kapitalgesellschaft (corporation) — even within the EU. Since the 2022 reform the unlimited deferral has fallen away. Main guide plus detail answers on avoidance, individuals, sole proprietorships and professional athletes.
The main guide
Wegzugsteuer 2026: how high, when due, how plannable
Wegzugsteuer in Germany 2026: who pays it, how high it is, which deferral applies and when the Wegzug becomes plannable. Main guide with worked examples, country comparison and timeline.
Read the full guideDetail answers
Concrete case constellations and detail questions around Wegzugsteuer — building on the main guide.
Avoiding Wegzugsteuer 2026: 7 Legal Strategies from Practice
Avoiding Wegzugsteuer is legally possible — provided the structures are in place three to five years before the Wegzug. Seven strategies from advisory practice, with worked examples and authority links.
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Wegzugsteuer for Privatpersonen 2026: When It Really Applies
Wegzugsteuer for Privatpersonen is often misunderstood. Anyone leaving as a pure investor is usually not affected — anyone holding shareholdings is. Here the delimitation with worked examples.
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Wegzugsteuer sole traders 2026: Entstrickung and the Betriebsstaette
Wegzugsteuer hits sole traders differently from GmbH shareholders — via § 4 Abs. 1 Satz 3 EStG (Entstrickung). Here the practitioner's overview with avoidance through the Betriebsstaette.
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Wegzugsteuer Profisportler 2026: Monaco, Switzerland, Image-GmbH
Profisportler with their own image-rights GmbH fall under § 6 AStG when leaving Germany for Monaco or Switzerland. Here the practice for tennis, football, esport and motor sport.
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Wegzugsbesteuerung § 6 AStG 2026: Deferral and Return
Wegzugsbesteuerung under § 6 AStG hits GmbH shareholders from a 1 % stake the moment they leave Germany. Deferral, return rules and destination countries in a practitioner's overview.
Read moreFrequently asked questions
The questions clients ask most frequently in advisory work around Wegzugsteuer.
Who has to pay the Wegzugsteuer?
Anyone unlimitedly tax-liable in Germany with at least 1 percent participation in a Kapitalgesellschaft (corporation) and 7 years of tax residency in the last 12 years (§ 6 AStG). Departures within the EU are now also affected since the 2022 reform.
How is the Wegzugsteuer calculated?
Fictitious sale at fair value at the time of departure. Tax base: hidden reserves (Stille Reserven). Tax rate: regular capital-gains tax under Teileinkünfteverfahren — for high incomes around 28 percent of the hidden reserves.
Is there still a Stundung (deferral)?
Yes — but only the new tiered Stundung over 7 years (§ 6 (4) AStG). Each year, 1/7 of the tax is due. Security deposit required. The old unlimited interest-free deferral for EU departures has been abolished since 2022.
How can the Wegzugsteuer be avoided?
Five tested routes: (1) restructuring into a Personengesellschaft (partnership) before departure, (2) Familienstiftung (family foundation) before departure, (3) temporary departure (7 years rule, § 6 (3) AStG), (4) reduction to under 1 percent before departure, (5) restructuring into asset-managing structures.
Structure your concrete situation
In the initial consultation we clarify your wealth and family situation, examine the suitable strategy and develop a concrete roadmap — without legal idling.
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