Private shareholdings
Material shareholdings may trigger exit taxation even where no sale takes place.
Exit Tax & Relocation
Relocation requires more than a new address.
For entrepreneurs, shareholders and wealthy individuals, the destination country is only one part of the analysis. German follow-up rules, shareholdings, hidden reserves, residence, material domestic interests and documentation must be reviewed before implementation.
When it becomes relevant
Relocation to the UAE or other third countries
A visa, apartment or foreign company does not by itself establish a reliable tax relocation.
Remaining German links
Real estate, participations, management functions, family, bank accounts or mandates may remain relevant.
Review questions
- Which shareholdings, hidden reserves and assets exist before relocation?
- Do exit tax rules, extended limited tax liability or other foreign tax rules apply?
- Where will the actual centre of life be located and how can it be documented?
- Will effective management, permanent establishments, material interests or income sources remain in Germany?
- Which timelines, deferral questions, cooperation duties and documentation points must be addressed before implementation?
Outcome
- Relocation and exit-tax check with risk levels and open items.
- Document list for tax advisers, banks, immigration, entities and family office.
- Timeline for relocation, restructuring, valuations and tax coordination.