Sec. 6 AStG, German exit taxation
Pick a profile. See the bill.
Ending German tax residency with a shareholding of 1% or more triggers an immediate tax on unrealised gains. Slide enterprise value, shareholding and acquisition cost; the destination toggle decides the deferral path.
Pick a starting scenario
Estimated exit tax
€0
Effective rate on full gain.
Deferral path
Show breakdown
Pro-rata enterprise value€0
Acquisition cost€0
Hidden reserves (gain)€0
Taxable share (60% rule)€0
Tax bill€0
Methodology and assumptions
- Sec. 6 AStG triggers exit tax on shareholdings of 1% or more held within the past five years when unlimited German tax liability ends.
- Tax base: fair market value at departure less acquisition cost. The Teileinkünfteverfahren applies, so 60% of the gain is included in taxable income.
- Default 47.5% reflects the top bracket (45% plus 5.5% solidarity surcharge). Church tax not modelled.
- EU/EEA destination. Post-2022 reform: 7-year interest-free instalment under § 6(4) AStG.
- Switzerland. 5-year instalment against security, settled by the German-Swiss agreement after the Wächtler ECJ judgment.
- Non-EU/EEA. Tax due immediately. Discretionary deferral against security rarely granted in practice.
- Re-establishment of unlimited German tax liability within seven years (twelve with extension) cancels the assessment under § 6(3) AStG.
Disclaimer
Indicative figures based on Sec. 6 AStG as currently in force. Not legal, tax, or investment advice. Always coordinate the move with a German tax adviser before deregistering.
Planning a move from Germany?
The sequencing matters more than the destination.
Thirty minutes. We work backwards from your departure date and identify the structuring window that exists, if any, before the move triggers Sec. 6 AStG.