“Crypto gains are tax-free in Georgia” is true — and still only half the answer. Whether you benefit from the 0% is decided not in Tbilisi but in the country you leave, and before the sale. Germany and Austria treat the same event in opposite ways: Austria settles up at the border, Germany lets the coins leave — but since 2025 reaches the fund portfolio beside them. This article sets out both starting positions, the sequence that makes the difference, and the banking side, without which the whole exercise fails at the first transfer.
What Georgia taxes — and what it does not
The Georgian side is quickly told, because it contains no special regime for crypto and simply applies the general system. Georgia taxes resident individuals territorially: income without a Georgian source remains exempt under Art. 82 of the Tax Code. Selling cryptocurrency on a foreign exchange has no Georgian source. The rate is therefore zero, irrespective of holding period, volume and number of transactions. VAT does not arise either.
Two boundaries belong with that, so the statement holds. It applies to the private individual, not to commercial trading and not to companies — anyone acting as a service provider for third parties lands in the National Bank’s VASP regulation. And it applies to the tax resident; anyone not meeting the residency test has no Georgian taxing right on their side, only a place of stay. The full picture including VASP regulation and banking practice is in Crypto in Georgia.
The German starting position: a holding period due to fall
For those resident in Germany the position is more comfortable than this industry’s marketing suggests — which is precisely why the arithmetic has to be honest.
Privately held cryptocurrencies are “other assets” within the meaning of § 23 EStG. The gain on sale is exempt after a holding period of one year; within the year a threshold of EUR 1,000 applies to all private disposals in the calendar year taken together, raised from EUR 600 by the Growth Opportunities Act. The Federal Ministry of Finance circular of 6 March 2025 also ended the debate about an extension to ten years for staking and lending — one year stands — and noticeably tightened the documentation requirements.
There is currently no exit taxation on crypto. § 6 AStG covers shares within the meaning of § 17 EStG, holdings of one per cent or more in corporations; privately held coins are not covered. That sentence is narrower than it sounds, however — and anyone extending it to their whole portfolio pays for it.
The holding period, too, is in play, and the position is more precise than the headlines suggest. At the coalition meeting of 12 April 2026 the Chancellor and the Federal Finance Minister agreed on the reform; the cabinet adopted the benchmark figures for the 2027 budget on 6 July 2026. Under those, privately held crypto assets are to be assigned to investment income and charged to capital gains tax — roughly 26.375 per cent including solidarity surcharge instead of the personal rate — with planned effect from 1 January 2027.
None of that is enacted. The Annual Tax Act 2026, adopted by the cabinet on 12 August 2026, does not contain the amendment to § 23 EStG, and no departmental draft on crypto taxation was available at the time of writing. The 1 January 2027 date is therefore no longer secure — the reform would need its own legislative route. A competing bill from the Greens (BT-Drs. 21/5752 of 6 May 2026) would have kept crypto assets within § 23 EStG and charged the personal rate of up to 45 per cent; it did not find a majority. Exit taxation on crypto assets has so far been demanded only by the Left faction in a motion (BT-Drs. 21/05824 of 7 May 2026) — that is not a government bill.
The Austrian starting position: the clock runs backwards
For those resident in Austria the position is fundamentally different, and it is regularly confused with the German one.
Since the eco-social tax reform act, cryptocurrencies count as investment income (§ 27b EStG). For coins acquired on or after 1 March 2021 — new holdings — the special rate of 27.5 per cent applies, with no holding period and from the first euro. Only old holdings acquired before that date remain exempt, the speculation period having long expired.
The second provision is the decisive one: § 27 para. 6 EStG treats departure as a realisation. Unrealised gains in investment assets — shares, fund units, derivatives and indeed cryptocurrencies — are valued at the date of departure and set against acquisition cost. On departure to an EU or EEA state the tax can, on application, initially not be assessed. On departure to a third country such as Georgia that option does not exist — the tax on the entire accrued gain falls due immediately.
| Germany | Austria | |
|---|---|---|
| Rate on private crypto gains | personal rate up to 45% within the holding period | 27.5% special rate |
| Holding period Austrian holdings acquired before 1.3.2021 remain exempt | 1 year, exempt thereafter (§ 23 EStG) | none — for acquisitions from 1.3.2021 |
| De minimis threshold | EUR 1,000 per calendar year | none for new holdings |
| Exit taxation on crypto § 6 AStG covers only shares under § 17 EStG; § 27 para. 6 EStG covers investment assets including crypto | ||
| Exit taxation on privately held funds and ETFs in Germany from EUR 500,000 acquisition cost per fund, or ≥ 1% of the units issued within the preceding five years | yes — since 1.1.2025 (§ 19 para. 3 InvStG) | yes — § 27 para. 6 EStG |
| Deferral on departure to Georgia in Germany by analogous application of § 6 para. 4 AStG, as a rule against security, with no EU/EEA versus third-country distinction | for fund units: seven annual instalments on application | no — non-assessment only for the EU/EEA |
| What the move achieves | secures future gains against the planned reform | caps the legacy, frees everything future |
For the Austrian holder that means, soberly: the move does not make historic gains tax-free. It draws a line under them — at 27.5 per cent, immediately — and frees everything that accrues afterwards. Whether that pays off is purely a question of time and expectation: the larger the expected future increase relative to the gain already accrued, the clearer the answer. Anyone already sitting on large unrealised gains and expecting no further growth saves nothing by leaving.
The sequence
From both positions follows an order that cannot be rearranged without losing the effect.
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Dissolve the home-country connecting factors, demonstrably
Residence and habitual abode do not end through deregistration but through surrendering control over a dwelling. Termination, handover record and cancellation with utility providers belong in the file. Austrians keeping a flat additionally need the register under the Zweitwohnsitzverordnung.
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Austria: calculate the exit tax, do not discover it
Unrealised gains in new holdings are valued at the departure date. Anyone who knows that date can place it in a year with a low price level or after realised losses, and treat old holdings separately beforehand. Anyone who does not plan it has it assigned to them.
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Acquire Georgian residency and have it certified
183 days in any twelve-month period, then apply to the Revenue Service for the certificate of residency — per tax year. Around 95 nationalities may stay visa-free for 365 days for this purpose; a residence permit is not required.
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Prepare the banking relationship and source of funds
Before the first off-ramp, not after. The bank examines the origin of funds across the whole chain: original acquisition, exchange statements, wallet addresses, transaction history. A chain with gaps does not lead to follow-up questions but to a rejected credit.
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Sell — and document the date
Only now. The date of sale, the certificate of residency for the relevant tax year and the evidence that the home-country connection ended together form the record you will need years later — before an authority that does not carry the burden of proof.
The account is the other half
A tax-free sale that lands in no account is not a tax-free sale. This is where most projects fail — not on tax law but on a European bank that either refuses a six-figure crypto-related credit or closes the account as a precaution.
Georgian banks behave differently here, not out of laxity but because the National Bank has provided a regulated framework for crypto service providers since 2023. TBC and BasisBank regularly work with on- and off-ramps via licensed exchanges; HashBank, licensed as a digital bank since 2024, integrates the purchase, sale and custody of common assets directly into the account. A private account is opened with a passport and proof of address from your home country no older than three months — a Georgian residence is not required, nor is any business connection. EUR, USD and GEL run in parallel on the same account; a multi-currency account is standard there, not an add-on product.
- Permitted: on- and off-ramps via licensed exchanges, incoming trading profits, transfers via licensed custodians
- Not permitted: direct transfers from wallets without a KYC trail, coins with mixer history, commercial activity without the matching registration
- Have the evidence chain ready: original acquisition, complete exchange statements, wallet addresses, transaction history — the bank reviews periodically, not only at onboarding
- Announce volumes in advance: a notified credit is reviewed, an unannounced one is held
- Trying to avoid reporting: Georgia has implemented CRS since 2023, exchange has run annually since 2024 and is extended by CRS 2.0 from 2026 — crypto exposure included
That last point is not small print but the core of the model. As long as you are tax resident in Germany or Austria, your Georgian account is reported to the authority there. Only once residency actually lies in Georgia does reporting abroad fall away — not because something is hidden, but because CRS captures accounts of persons with tax residence in another country. The model works because of transparency, not despite it. The full picture is in CRS and Georgia, and account opening step by step in Opening a bank account in Georgia.
A fresh start after insolvency — what an account does and does not do
Part of the demand for accounts outside the EU comes from a different situation: after account attachment, after insolvency, after an account closure without reasons given. Those cases deserve a clear answer rather than a promise.
A Georgian account sits outside the direct reach of the European Account Preservation Order. That is a fact about jurisdiction and procedure, not invisibility. Disclosure and cooperation duties in insolvency proceedings apply regardless of where an account is held, and concealing assets from the insolvency administrator or the court is a criminal offence — wherever the account sits. Moving assets during ongoing proceedings risks the refusal of discharge, and more.
The viable use cases are different ones — and all the stronger for it:
- After discharge of residual debt has been granted: an account with an institution that does not query a German credit bureau — the practical fresh start many are looking for first
- Ahead of emigration: the infrastructure is in place before it is needed — account, card, multi-currency, without time pressure in the month of the move
- As a second banking relationship outside home-country banking: operational capacity if one institution closes without warning
- As a reserve outside the euro area, fully declared in the relevant tax return schedule
What an account attachment actually reaches, and where its limits lie, is set out in How far account attachment really reaches; why banks may not tell you the reason for a freeze, in Your bank is not allowed to tell you why.
What follows from this
The Georgian cash-out is not a trick but a question of timing. The tax burden is decided on the day you sell, and your tax status on that day is the result of decisions taken months earlier: when the home-country dwelling is actually given up, when the 183 days are complete, when the certificate of residency is in hand, and whether the bank accepts the source of funds.
For German holders with long-term positions the honest finding is: on the crypto side the step achieves little for the past and possibly a great deal for the future — depending on what becomes of the 2027 budget benchmarks. On the portfolio side the calculation is already a different one today: from EUR 500,000 of acquisition cost per fund, § 19 para. 3 InvStG bites on departure, and that position belongs calculated before a date is set. For Austrian holders it is a calculation with two known quantities: 27.5 per cent on what exists against zero on everything further. All three calculations can be run on your own figures in half an hour — knowing in advance which applies is half the work.
How the move runs overall is in the twelve-month plan in Moving to Georgia; the residency requirements in detail in Tax residency in Georgia.
Frequently asked questions
Are private crypto gains really tax-free in Georgia?
For private individuals, yes. Georgia taxes resident individuals territorially: income without a Georgian source remains exempt under Art. 82 of the Tax Code, and selling cryptocurrency on a foreign exchange is not a Georgian source. The sale is also outside VAT. That applies to the private individual — not to commercial trading and not to companies, where the ordinary rules apply including VASP registration for relevant activity.
When exactly does the exemption begin?
On the day you are a Georgian tax resident and no residency remains in Germany or Austria — not on the day you arrive. Georgia establishes residency after 183 days in any twelve-month period, or through the HNWI programme. Selling before that means selling under the old regime. This gap between moving and residency is the most expensive mistake in the whole exercise, and planning removes it entirely.
Does leaving Germany trigger exit taxation on crypto?
For privately held cryptocurrencies, currently not: § 6 AStG covers shares within the meaning of § 17 EStG, meaning holdings of one per cent or more in corporations, and coins are not covered. That no longer holds for the rest of your portfolio, however. Since 1 January 2025, § 19 para. 3 InvStG treats giving up residence as a deemed disposal of investment fund units held privately — retail funds and ETFs included — where you held at least 1 per cent of the units issued within the preceding five years, or hold units with acquisition costs of EUR 500,000 or more per fund. The tax may be paid in seven annual instalments on application. Anyone planning only the crypto side misses the more expensive half.
Will the German crypto holding period be abolished — and when?
Politically the direction is set; legally nothing is decided. Following the coalition meeting of 12 April 2026, the cabinet adopted the benchmark figures for the 2027 budget on 6 July 2026: privately held crypto assets are to be assigned to investment income and charged roughly 26.375 per cent capital gains tax including solidarity surcharge, planned from the 2027 assessment period. The Annual Tax Act 2026, adopted by the cabinet on 12 August 2026, does not however contain the amendment to § 23 EStG, and no departmental draft was available at the time of writing — the 1 January 2027 date is therefore not secure. On grandfathering: increases in value that arose before promulgation and could be realised tax-free under the old law may not be captured retrospectively, per the case law of the Federal Constitutional Court (decision of 7 July 2010, 2 BvL 14/02).
And on leaving Austria?
There the position is fundamentally different. Since the eco-social tax reform act, cryptocurrencies count as investment income (§ 27b EStG) and are subject to the special rate of 27.5 per cent with no holding period, where acquired on or after 1 March 2021. Departure triggers taxation of unrealised gains under § 27 para. 6 EStG. The application for non-assessment is available only on departure to an EU or EEA state — on departure to Georgia the tax on the entire accrued gain falls due immediately. Holdings acquired before 1 March 2021 are not affected.
Which Georgian banks accept crypto-derived funds?
TBC and BasisBank regularly work with clients using on- and off-ramps via licensed exchanges such as Binance, Kraken or Bitstamp. HashBank, licensed as a digital bank by the National Bank since 2024, integrates crypto trading directly into the bank account. In every case a robust source-of-funds record is required. Not accepted are direct transfers from wallets without a KYC trail and coins with mixer history. A private account is opened with a passport and proof of address, without a Georgian residence and without any business connection.
Does a Georgian account protect against creditors or ongoing enforcement?
No — and anyone promising that is selling a risk as a product. An account outside the EU sits outside the direct reach of the European Account Preservation Order, but disclosure and cooperation duties in insolvency proceedings apply regardless of where an account is held, and concealing assets is a criminal offence. Such an account makes sense after discharge of residual debt has been granted — a fresh start with an institution that does not query a German credit bureau — and as infrastructure prepared ahead of emigration. Both are legitimate, fully declared use cases.
This article is general information and does not constitute legal or tax advice. The German statements refer to § 23 EStG, § 6 AStG, § 19 para. 3 and § 49 para. 5 InvStG as amended by the Annual Tax Act 2024, and the Federal Ministry of Finance circular on individual questions of the income tax treatment of crypto assets of 6 March 2025; the reference to the planned abolition of the holding period relates to the 2027 budget benchmarks adopted by the cabinet on 6 July 2026, which are not law at the time of writing and were not contained in the Annual Tax Act 2026. The Austrian statements refer to §§ 27, 27a and 27b EStG as amended by the eco-social tax reform act. The Georgian statements refer to the Tax Code (Art. 82) and the VASP regulation of the National Bank of Georgia. Anyone who is or remains taxable in Germany, Austria or Switzerland must fully declare foreign accounts and income there — always involve a tax adviser in your home country before relocating or disposing. As of August 2026, subject to changes in law.