Extended limited tax liability: ten years after you leave
German nationals who move to a low-tax territory and keep substantial economic interests at home stay liable on an extended basis for up to ten years.
Insights on company formation, banking and taxes in Georgia.
German nationals who move to a low-tax territory and keep substantial economic interests at home stay liable on an extended basis for up to ten years.
Residence alone does not hold tax liability — habitual abode is a separate connecting factor.
Austria taxes departure under section 27(6) of the Income Tax Act. Within the EU and EEA it can be paid in instalments — for Georgia it falls due at once.
Holding shares in a corporation triggers a deemed capital gain when you leave Germany. What the rule catches, and which payment reliefs exist.
Section 2 ErbStG keeps German nationals within domestic inheritance tax for five years after departure.
Departure ends statutory health insurance membership. Section 6 (3a) SGB V bars re-entry from age 55 — and since 1 January 2026 foreign cover cannot help.
Germany taxes departure under section 6 AStG, Austria under section 27(6) EStG — due immediately for third countries.
Liquidate a company in Georgia (country): LLC liquidation, I/E deregistration, share sale or US LLC dissolution — steps, checklist and typical risks.