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Since 2022 the “everlasting deferral” for exits from Germany has also been rescinded and not replaced for changes to residence within Europe. Businesspeople and natural persons with shares in corporations of more than one percent now have to pay exit tax straight away. Distributing this in instalments over seven years is only a little help with liquidity planning be-cause the tax authorities usually require the full amount to be paid up front as security. A Polish court has now referred three questions to the ECJ, which, with regard to the European law concerns, could also be relevant to Germans moving abroad.

The German Bundestag has introduced exit taxation on investments at record speed. The Bundesrat, the upper house, didn’t ratify yet but is expected to assent to the new rules so that they might enter into force starting on 1 January 2025.

Asset management GmbHs (companies with limited liability) are still the subject of discussion. Many asset managers, trading platforms and investment consultants talk this structure up as a “tax-saving model”. But what’s actually behind it? Let’s have a look at the law and how it’s implemented in practice.

In this article, you can read about the challenges that arise when preparing a purchase price allocation.

The court clarifies that that a temporary absence and the associated annulment of exit taxation also applies if there was no intention to return at the time of leaving Germany. What this means in practice.