Moving abroad with shares in a German GmbH? Germany taxes a deemed sale at fair market value on the day you leave. I value your shares under IDW S 1, the German valuation standard, so you can prove a lower value than the tax office's simplified approach.
In short: Under § 6 AStG, moving your residence abroad is treated as selling your shares at fair market value. Without your own evidence, the tax office uses a simplified formula with a fixed factor of 13.75 that ignores company-specific risk. A valuation report under IDW S 1 can prove a lower value (§ 11 (2) BewG). Fixed fee from EUR 9,700 plus VAT, 2 to 4 weeks after complete documents.
You hold at least 1 % in a corporation such as a GmbH, UG or AG (§ 17 EStG), you have been subject to unlimited tax liability in Germany for at least seven of the last twelve years, and you move your residence or habitual abode abroad. § 6 AStG then taxes the increase in value of your shares as if you had sold them, although no buyer exists and no cash flows. Since 2022 this applies to moves within the EU as well, without permanent deferral.
Without a valuation report, the tax office usually applies the simplified income approach (§§ 199 ff. BewG): the average annual result, reduced by a flat 30 % for income taxes, multiplied by a fixed capitalisation factor of 13.75 (§ 203 BewG). The factor corresponds to a discount rate of about 7.3 % and does not reflect the risk of your business. § 11 (2) BewG allows you to prove a lower fair market value. The net asset value remains the floor.
| Example | Amount |
|---|---|
| Average annual result before taxes | EUR 400,000 |
| After flat 30 % income taxes | EUR 280,000 |
| × factor 13.75 = tax office value | EUR 3,850,000 |
Simplified illustration of the formula in §§ 201 to 203 BewG. Whether a lower value can be proven depends on the individual business.
We can talk in English. The report itself is written in German, the language of the German tax authorities. I work alongside your tax adviser, who files the exit tax return. Tax advice is not part of my service.
I am Yannick Maar, Certified Valuation Analyst (CVA) and independent business valuer based in Erkelenz near Düsseldorf, working throughout Germany. Former audit senior at Deloitte, member of the EACVA and co-author of an article on the 2026 version of IDW S 1 in BewertungsPraktiker 03/2026. More in German: Über mich.
Individuals who hold at least 1 % in a corporation (§ 17 EStG), have been subject to unlimited tax liability in Germany for at least seven of the last twelve years, and move their residence abroad (§ 6 AStG). The move is treated as a sale of the shares at fair market value.
Usually with the simplified income approach of §§ 199 ff. BewG: average annual result, reduced by a flat 30 % for income taxes, multiplied by a fixed factor of 13.75. This often leads to a value above the market value. § 11 (2) BewG allows the taxpayer to prove a lower value, for example with a valuation report under IDW S 1. The net asset value remains the floor.
On application, in seven equal annual instalments, usually against security (§ 6 (4) AStG). If you return to Germany within seven years (extendable on application by up to five years) and the conditions of § 6 (3) AStG are met, the tax lapses. Your tax adviser checks the conditions.
Section 6 AStG applies only to shares in corporations. For business assets of a sole proprietor, § 16 (3a) EStG may apply if Germany loses the right to tax the business assets. The assets are then valued individually at fair market value.