Purpose
Exit tax planning starts before the move, not when a tax assessment arrives. The review identifies whether a shareholder, founder or family member holds interests that can trigger German exit taxation when residence or treaty access changes.
Knowledge
Exit tax review for German shareholders before relocation.
A focused review of German exit tax exposure, residence, shareholdings, deferral options and implementation risks before relocation.
Review points
The file should show the participation history, percentage ownership, acquisition costs, fair market value, family transfers, residence history, treaty position, intended move date and whether a return to Germany is realistic. We also check whether a holding, partnership, foundation or liquidity event changes the tax result.
Typical output
The outcome is a decision file: exposure map, assumptions, valuation questions, deferral or instalment options, risks that cannot be removed, and the documents needed for tax advisers, banks and implementation partners.
Why it matters
Exit tax is rarely an isolated issue. It affects estate planning, bankability, CFC analysis, company management, future dividends and the ability to sell or restructure later. The structure must therefore be reviewed as one system.
Next step
Turn the topic into a documented review.
Confirm facts and jurisdictionsPrepare ownership and bank documentsMap tax, governance and implementation risksBook a confidential consultation