Subject area
Leaving & tax liability
Most mistakes people make when leaving are mistakes of sequence. This area sorts out what has to be settled first and what carries on afterwards.
The most expensive sentence in this subject area is “but I deregistered”. Deregistration is an administrative act. Tax liability follows its own rules, and several of them outlast the move.
What you will find here
Before leaving. The questions that have to be answered first — above all the valuation of company shareholdings, because the cut-off date cannot be revisited. Plus the order in which a departure runs without anything falling through.
After leaving. The duties that remain: extended limited tax liability, controlled-foreign- company rules for entities you control, inheritance tax, health cover, and how German authorities treat a Georgian company.
The myths. The 183-day rule is misquoted more often than not, and “living stateless” describes an arrangement that usually ends differently in tax law than in the brochure.
Where our competence ends
We are a corporate service provider in Georgia, not German, Austrian or Swiss professionals. The articles here explain what to watch for and which questions you have to ask — they do not replace an assessment of your case in the country you are leaving.
In practice: we build and run the structure in Georgia. Whether your departure holds up for tax is judged by someone licensed in the country you leave.
Articles in this subject area
- Exit taxation: the calculation that belongs before the move Holding shares in a corporation triggers a deemed capital gain when you leave Germany. What the rule catches, which payment reliefs exist, and why the valuation date cannot be revisited.
- 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. The conditions, and what they mean in practice.
- Habitual abode: the underestimated anchor of tax liability Residence alone does not hold tax liability — habitual abode is a separate connecting factor. What creates it, how it differs from the 183-day rule, and why deregistering does not end it.
- Leaving Austria: why Georgia makes the tax due at once Austria taxes departure under section 27(6) of the Income Tax Act. Within the EU and EEA the tax can be paid in instalments on application — for a third country such as Georgia it falls due immediately. What that means for planning.
- From Spain to Georgia: what the 183 days do not settle Georgian residence does not end Spanish residence. What decides an exit is the 2010 convention, the baja and the centre of your life — not the day counter. The good news: Georgia is not on Spain’s list of non-cooperative jurisdictions.
- Moving Within the EU: The Judgment Travels With You Bulgaria taxes income at 10 percent — and throws in the EU Service Regulation, the European order for payment and enforcement without exequatur. Anyone keeping German and Austrian clients relocates their residence, not their legal environment.
- A €15,136 Ceiling — and Co-Payments Up by Half The German statutory maximum contribution is €1,261.31 a month in 2026. The Contribution Rate Stabilisation Act of 10 July 2026 raises co-payments by half, cuts dental subsidies and ends free family cover for childless spouses. What a Georgian policy costs — and where the comparison stops working.
- Retiring in Georgia: a €1,405 Pension Against a €781 Wage The average German pension is 1.8 times the Georgian average wage. What the double taxation treaty assigns to whom, why the "70 percent cut" is a myth — and the age limit at which the whole model can fail.
- Georgian LLC, German Residence: the Active-Income Test Anyone living in Germany who controls a Georgian LLC cannot avoid §§ 7–13 AStG. The substance defence is closed to third countries — only the active-income catalogue counts. What applies to trade, services and manufacturing, and why Austria calculates differently.
- Perpetual Traveller: Counting 183 Days Is Not Enough Perpetual travellers count days in the host country — and miss the two counters that keep running in Germany and Austria. What still applies after leaving, and why the rotation does not hold without a documented tax residency.
- Five Years After You Leave, the Tax Office Still Inherits Section 2 ErbStG keeps German nationals within domestic inheritance tax for five years after departure. Switzerland voted 78.3% against, Austria rejected it — Karlsruhe hears the case in October.
- Leaving the Scheme Is Easy. Getting Back In Is Not Departure ends statutory health insurance membership. Section 6 (3a) SGB V bars re-entry from age 55 — and since 1 January 2026 equivalent foreign cover no longer helps.
- Emigration: 8.2 Million Germans — What Leaving Costs INSA survey July 2026: 14% plan to emigrate within five years. What the numbers support — and what German exit tax under § 6 AStG and § 2 AStG really means.
- Georgian Company, German Authorities: What Actually Counts Place of management, market-effects principle, Art. 3 GDPR: four regimes tested — where a Georgian company holds up and where only a genuine relocation helps.
- Staying Does Not Get Cheaper. Leaving Gets More Expensive Germany taxes departure under section 6 AStG, Austria under section 27(6) EStG — due immediately for third countries. The response to emigration is not relief.
- "Stateless" Is Not a Solution — It Is a Banking Problem The perpetual traveller fails not on tax but on onboarding. Every bank wants an address, every report a tax number, every treaty a residence.
- Relocate to Georgia: 365 Visa-Free Days Move to Georgia (country): 365 days visa-free, company setup in 1 day, tax residency after 183 days. Your month-by-month relocation roadmap for 2026.