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Moving from Germany Tax Guide 2026: Wegzugsteuer Exit Tax, Church Tax & Riester-Rente

Quick Answer: Germany has one of Europe's most significant exit taxes — the Wegzugsteuer under §6 AStG taxes unrealised gains on GmbH, UG, or AG shares if you hold more than 1% and are leaving Germany permanently. Outside of private company shares, Germany does not tax unrealised gains on securities portfolios or real estate on departure. Key administrative steps: Abmeldung (deregistration from Einwohnermeldeamt), Kirchenaustritt if you pay church tax, and a final German income tax return. Riester-Rente subsidies (Zulagen) must be repaid in full if you permanently leave Germany.
By Daniel, founder of CountryTaxCalc.com

Last Updated: April 2026

Key Facts

Wegzugsteuer §6 AStG: Germany's Exit Tax on Private Company Shares
Germany's Wegzugsteuer (exit tax) under §6 AStG applies when you permanently leave Germany and you hold, or held in the previous 5 years, at least 1% of shares in a corporation (GmbH, UG, AG, SE, or equivalent foreign corporation). The tax: all unrealised gains in those shares are treated as realised at FMV on the day before departure. Taxed at the personal income tax rate (up to 45% plus solidarity surcharge — though for qualifying shareholdings held as business assets, the flat 25% Abgeltungsteuer does not apply). Calculation: (FMV on departure date) − (original cost/acquisition price) × your German income tax rate. EU/EEA deferral: if you are moving to another EU or EEA country, you can request that the exit tax be deferred interest-free until the shares are actually sold. Non-EU departure (USA, UK post-Brexit, Switzerland, UAE): no automatic deferral — the tax is due by the normal July 31 tax filing deadline. Payment in instalments: you can apply to the Finanzamt to pay in up to 5 annual instalments (with interest) for non-EU departures, provided adequate security is given. The 1% threshold includes shares held directly and via attribution rules (family members). Check carefully if you hold any GmbH shares before departure.
Kirchenaustritt: Church Tax Deregistration
Germany's Kirchensteuer (church tax) is collected by the state on behalf of recognised churches (Catholic, Protestant, and others). It adds 8–9% on top of your income tax liability (the exact rate depends on the federal state: Bavaria and Baden-Württemberg use 8%; other states use 9%). If you are registered in Germany as a member of a church that levies Kirchensteuer, you are paying it automatically via your payroll deductions or annual tax assessment. To leave the church tax system — either before or after departure: complete a formal Kirchenaustritt (church exit declaration) at the local civil registry (Standesamt or Amtsgericht). This is a legal civil act, separate from any religious decision. Cost: €10–€30 administrative fee (varies by state). Effect: Kirchensteuer stops from the following month after registration. Important for departures: Kirchensteuer is assessed on your German income up to your departure date. If you deregister (Abmeldung) without doing a Kirchenaustritt, you may receive a final Kirchensteuer assessment for the remaining period. Given that Kirchensteuer can represent ~0.7–1.2% of gross income, doing the Kirchenaustritt before final departure saves a meaningful amount for high earners.
Riester-Rente and State-Subsidised Pensions: Repayment on Departure
The Riester-Rente is Germany's state-subsidised private pension scheme. Contributions attract direct government subsidies (Zulagen): €175/year basic allowance plus €185–€300 per child. Additionally, Riester contributions qualify for the Sonderausgaben deduction in your German tax return (up to €2,100/year). When you permanently leave Germany (or the EU/EEA): all Zulagen received and all tax advantages claimed (Sonderausgaben deductions) must be repaid in full to the Zentrale Zulagenstelle für Altersvermögen (ZfA). This is called 'schädliche Verwendung' (harmful use). The repayment can be substantial for long-term Riester savers. The repayment does not apply if you move to another EU/EEA country where the German-EU rules preserve the subsidy. For non-EU departures (USA, UK, UAE): repayment is mandatory. Your Riester provider will receive notification from ZfA and deduct the repayment from your accumulated balance. What remains is still your own contributions plus investment returns (net of repaid subsidies). You can either liquidate the plan (paying income tax on the capital) or continue to hold it (frozen, no further contributions) — taking the payout in Germany while a non-resident triggers withholding.
Deutsche Rentenversicherung: German State Pension Abroad
Germany's statutory pension insurance (Deutsche Rentenversicherung — DRV) covers most employees. Your accrued pension entitlement (Rentenanspruch) is preserved on departure — you do not lose it. Pension payment abroad: DRV pays state pension internationally. To receive your German pension abroad, contact DRV at www.deutsche-rentenversicherung.de. The pension is paid in EUR and converted to local currency by the recipient's bank. German pension age: currently 67 for those born after 1964 (early access at 63 with 45 contribution years). German pension withheld at source: a 7.65% solidarity contribution + health contribution applies to DRV pensions for German residents; non-residents are generally exempt from the health contribution — this slightly increases the net pension amount for non-residents. Voluntary contributions: if you leave Germany with fewer than 5 contribution years, your DRV credits are forfeited (you receive a refund of your personal contributions only — employer contributions are not refunded). With 5+ years: the full pension is preserved. Totalization: Germany has bilateral social security agreements with many countries (including the USA, UK, Canada, Australia) — your German and foreign pension contribution years are combined to meet minimum eligibility thresholds.
Abmeldung and German Administrative Departure
Germany requires all residents to be registered (Anmeldung) at their local Einwohnermeldeamt (registration office). When leaving Germany permanently: you must Abmelden (deregister) at the Einwohnermeldeamt. Timing: do Abmeldung on your actual departure day or up to one week before. You receive a Abmeldebestätigung (deregistration confirmation) — keep this as proof of departure date for tax purposes. Tax implications: the Abmeldung confirms your German residency end date for the Finanzamt (tax office). Your German income tax obligation ends on your Abmeldung date. After Abmeldung: your German Steuer-ID (tax identification number) remains valid — you will need it to file your final German tax return. Final German income tax return: covers January 1 to Abmeldung date. Income from all worldwide sources for the German residency period is included. File by July 31 of the following year (or by February 28 if a tax advisor is engaged). After departure: non-resident status — only German-source income (rental, business income, dividends) is taxable in Germany, subject to relevant DTA provisions.

Germany is home to one of Europe's most internationally mobile professional classes — engineers, researchers, finance professionals, and entrepreneurs regularly move from Germany to the USA, Switzerland, the UK, UAE, and Asia. Germany's departure tax system is more targeted than Canada's or Australia's: it focuses specifically on private company shareholdings under §6 AStG (Aussensteuergesetz — the Foreign Tax Act), rather than imposing a broad deemed disposal on all assets. However, the Wegzugsteuer (exit tax) can be very significant for GmbH founders and shareholders, and the administrative requirements around Abmeldung, Kirchenaustritt, Riester, and final tax returns require careful timing.

Moving from Germany to the USA: Key Planning Points

Germany-to-USA is a major migration corridor — particularly for tech, engineering, and academic professionals. Key Germany-US planning points:

Wegzugsteuer timing for GmbH founders: If you hold GmbH shares and are moving to the USA, the exit tax is due immediately (no EU deferral applies). Consider whether to trigger the exit tax while still German-resident at lower German rates vs restructuring before departure. A sale of the GmbH before departure might be preferable to an exit tax assessment — German tax treatment of GmbH share sales under §17 EStG (40% tax-exempt via Teileinkünfteverfahren) may produce a better outcome than the pure exit tax calculation.

German-US Double Taxation Agreement: The 1989 Germany-USA DTA governs which country taxes what. German income (pension, rental, dividends) after departure: typically taxed in Germany with a Foreign Tax Credit available in the USA. Key article: the tiebreaker residence clause determines US residency vs German residency if there are competing claims.

Betriebliche Altersvorsorge (bAV — occupational pension): German employer pension plans are complex. Some are held as deferred compensation with the employer; others are via Pensionskasse or Direktversicherung. On departure: your accrued bAV entitlement is vested after 3 years of service — you cannot take it early but it will be paid at pension age. Check vesting status before departure.

PFAND (deposit) and contract cancellations: German mobile contracts, gym memberships, and certain insurance policies have Kündigungsfristen (notice periods) — typically 1–3 months. Cancel these 3 months before departure to avoid post-departure charges.

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Frequently Asked Questions

Q: I own 5% of a GmbH — how is the Wegzugsteuer calculated when I leave Germany?

The Wegzugsteuer is calculated as: (FMV of your GmbH shares on the day before departure − your original acquisition cost / Anschaffungskosten) × your applicable German income tax rate. GmbH share gains for holdings ≥1% are taxed under §17 EStG using the Teileinkünfteverfahren — 40% of the gain is tax-free, 60% is taxable at your marginal rate (up to 45% plus 5.5% solidarity surcharge). Example: FMV €500,000, cost base €50,000, taxable gain €450,000. Under Teileinkünfteverfahren: 60% taxable = €270,000. At 42% marginal rate: €113,400 plus soli = ~€119,600 tax. For a non-EU departure (USA): this tax is due by July 31. Apply to the Finanzamt for instalment payment if cash flow is a concern. Important: get an independent FMV valuation of the GmbH before departure — you and the Finanzamt may disagree on value, and a professional valuation supports your position.

Q: Do I owe German tax on my investment portfolio when I leave?

No — Germany does not have a general exit tax on investment portfolios (ETFs, stocks, bonds). The Wegzugsteuer under §6 AStG applies only to private company shareholdings ≥1%. Your ETF and stock portfolio held in a German Depot (brokerage account) is not subject to deemed disposal on departure. When you actually sell investments after departure: whether Germany can tax depends on the DTA with your new country of residence. Under most DTAs, capital gains on portfolio investments are taxable only in your country of residence (not Germany). German Abgeltungsteuer (25% flat tax) applies to investment income earned while German-resident — ceases on departure. After departure: check if your German bank continues to apply Abgeltungsteuer as a non-resident (they may need a Non-Resident certificate — Freistellungsauftrag changes) or release funds gross.

Q: When should I do the Kirchenaustritt — before or after departure?

Before departure is strongly recommended. The Kirchenaustritt takes effect from the month following the application. If you submit it on your last day in Germany, the effective date is the following month — and you may receive a final Kirchensteuer assessment for that period. To avoid all post-departure church tax, submit the Kirchenaustritt at least 1–2 months before your departure date. Go to your local Standesamt (civil registry office) or, in some states, the Amtsgericht (district court). You do not need to give a reason. Your Finanzamt will be notified automatically. If you have left Germany without doing a Kirchenaustritt: you can still complete it retroactively from abroad by contacting the Standesamt by post — some states accept foreign notarised declarations. The sooner you complete it, the lower the final assessment.

Q: What do I do with my German bank account after I leave?

You are allowed to maintain a German bank account (Girokonto) as a non-resident. Inform your bank of your change of address and tax residency status. Your bank may reclassify you as a non-resident customer — some banks close non-resident accounts (check your bank's terms). Deutsche Bank, Commerzbank, DKB, and ING Germany all have provisions for non-resident customers, though features may be reduced. Tax on interest: German banks apply Abgeltungsteuer (25%) to interest on German accounts. As a non-resident, you may be entitled to a reduced rate under your DTA — file a Freistellungsantrag at your local Finanzamt or request reduced withholding via the Bundeszentralamt für Steuern (BZSt). For USA non-residents: banks must report US persons' accounts to the IRS under FATCA; ensure your German bank has your correct US address and SSN/TIN. FBAR: German bank accounts over $10,000 must be reported annually via FinCEN Form 114 once you are a US resident.

Q: I have a German Bausparvertrag (building society savings contract) — what happens?

A Bausparvertrag (building society savings plan with Bausparkassen like Schwäbisch Hall or BHW) is a savings+loan product specifically for real estate in Germany. On departure: you generally have two options: (1) Continue to hold the Bauspar contract as a non-resident — savings continue to accrue interest (taxable in Germany); if you intend to buy German property in the future, the loan option remains valid. (2) Cancel the contract — you receive back your contributions plus interest, less any early cancellation penalty (Nichtabnahmeentschädigung if in loan phase). Wohnungsprämie (housing premium) from the state: claimable only for German residents in the claim year — you lose this on departure. State bonuses (Wohnungsbauprämie) already credited for past years are not repaid on departure (unlike Riester). Review the terms of your specific contract and how long you have held it before deciding.

Disclaimer: This guide provides general tax information for educational purposes only. The Wegzugsteuer rules under §6 AStG, Riester subsidy repayment calculations, and DRV pension rules are complex and change with German tax legislation. Nothing in this guide constitutes tax or legal advice. Consult a German Steuerberater (tax advisor) and, if moving to the USA, a cross-border tax specialist before departing Germany.

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