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Germany Applies Exit Tax When Tax Residency Changes

Published: 04.09.2026

Germany applies an exit-tax mechanism under which unrealized gains on shares, interests or businesses may be taxed when an individual loses tax residency. The market value of assets is recorded on the date residency changes; in some countries, application depends on asset value or the size of the ownership stake.

According to the source, leaving Germany and losing tax residency may trigger a tax assessment on unrealized capital gains even when the assets have not been sold. This is particularly relevant to owners of company interests, shares and businesses, because the tax event may arise when residency status changes rather than when an asset is sold. Anyone planning to relocate while holding substantial investment assets should check the applicable rules and thresholds in advance. The issue is less significant for employees without major ownership interests or investment portfolios.