A representative INSA survey published on 28 July 2026 reaches a striking result: 14 percent of German adults plan to leave the country within the next five years — around 8.2 million people. This article takes the numbers seriously but also sets out what a survey of intentions cannot show. And it covers the part reporting routinely leaves out: the expensive moment is not the arrival, it is the departure.
The numbers
The age distribution is the genuinely informative part of the survey:
| Age group | Share intending to emigrate |
|---|---|
| 18 – 29 years | 24% |
| 30 – 39 years | 27% |
| over 70 years | 4% |
The finding therefore concentrates in the cohorts that generate taxes and contributions, found companies and build families. A quarter or more of 18-to-39-year-olds actively consider leaving, while among the over-70s the figure is a negligible 4 percent.
The expensive moment is the departure
Anyone considering a move usually calculates the destination side: tax rate, cost of living, banking. The larger item routinely sits on the departure side — and it is time-dependent.
Exit taxation under § 6 AStG
Anyone holding at least 1 percent of a corporation who gives up their German residence is taxed as though they had sold the shares at the moment of departure. No money changes hands — the tax on the fictitious capital gain falls due regardless.
The mechanism in four points
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Deemed disposal
The increase in share value since acquisition is treated as realised at the moment of departure and subjected to income tax — with no cash inflow.
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1 percent threshold
Any shareholding from 1% within the meaning of § 17 EStG is caught. Since the Annual Tax Act 2024, investment fund and ETF units also fall within scope from 1 January 2025.
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Instalments instead of deferral
Since the ATAD Implementation Act 2022 there is no longer an indefinite interest-free deferral for EU/EEA departures. On application the tax is paid in seven annual instalments — regularly against security such as a bank guarantee or a pledge of the shares.
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Georgia as a third country
Georgia lies outside the EU and EEA, so EU-law reliefs do not apply — though the instalment solution applies uniformly to all cases.
Extended limited tax liability under § 2 AStG
The second, less-noticed point: Germany does not release departing taxpayers immediately. Under § 2 AStG, German nationals remain subject to extended limited tax liability for up to ten years after the year of departure, where three conditions are met cumulatively:
- Subject to unlimited tax liability as a German national for at least five of the ten years preceding departure
- Residence in a low-tax country under § 2(2) AStG — Georgia regularly qualifies under the abstract burden comparison
- Continuing substantial economic interests in Germany under § 2(3) AStG
In practice the provision only bites above a de-minimis threshold of EUR 16,500 of relevant income in the assessment period. The decisive lever is the third condition: anyone who genuinely winds down their economic interests in Germany no longer meets the cumulative requirements. A departure that leaves business, clients and assets substantially in Germany is, in tax terms, not a departure at all.
The sequence that works
Both points imply an unspectacular but effective order of operations — the one we have supported in Tbilisi since 2019:
Four stages, each testable on its own
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1 — Take stock with your tax adviser at home
Before any structure comes the question of whether § 6 AStG applies at all and how large the tax base would be today. That figure governs all further planning — and it can only be determined in your home country.
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2 — Build account and structure without leaving Germany
A Georgian bank account or company can be prepared while you remain tax resident in Germany — fully declared there. Accounts are reported via CRS in any case.
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3 — Test phase on the ground
Citizens of around 95 countries can stay in Georgia visa-free for 365 days. That is enough to assess the country, the banking and daily life before anything irreversible happens.
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4 — Relocation with genuine substance
Only then comes tax residency — centre of life, substance, wound-down domestic interests. That is exactly what separates a robust structure from one that will not survive an audit.
Further reading: Moving to Georgia, Georgia tax residency and — on the question of what a company achieves without an actual move — Georgian company, German authorities. The burden side in Germany is covered in German Tax Reform 2026.
Frequently asked questions
FAQ
Do 8.2 million Germans really want to emigrate?
The representative INSA survey of 28 July 2026 reports 14 percent of adults planning to emigrate within five years — extrapolated to roughly 8.2 million. It is a survey of intentions, not a migration forecast: 68 percent rule out leaving, 18 percent are undecided, and actual emigration figures are considerably lower.
What does exit tax under § 6 AStG cost?
It taxes the increase in value of your shares in corporations from a 1% holding as though you had sold at the moment of departure — without any cash flowing. The amount depends entirely on company value. On application, payment in seven annual instalments is possible, regularly against security. Only your tax adviser can determine the actual figure.
Does exit tax apply to ETFs as well?
Yes. The Annual Tax Act 2024 extended the scope to investment fund and ETF units with effect from 1 January 2025. A considerably wider group is therefore affected than before, not only shareholders in operating companies.
Am I out of German tax liability immediately after leaving?
Not necessarily. Under § 2 AStG, German nationals can face extended limited tax liability for up to ten years after the year of departure — where they move to a low-tax country and retain substantial economic interests in Germany. Anyone who genuinely winds down those domestic interests does not meet the cumulative conditions.
Do I have to emigrate immediately to change anything?
No. Account and structure can be built while you remain resident in Germany and subject to declaration there. The 365 days of visa-free stay allow an extensive test phase. What cannot be shortened is the tax preparation of the departure itself — that belongs at the beginning, not the end.
This article is general information and does not constitute legal or tax advice. Exit taxation, extended limited tax liability and giving up residence are case-specific questions with significant financial consequences — you must involve a tax adviser in your home country. As of August 2026, subject to changes in the legal situation.