From Germany to Italy

Leaving Germany

• Residence (Wohnsitz, s. 8 AO). You are resident if you have a home in Germany that you keep and can use, owned or rented. Even a room kept available for you can count. Days spent are not decisive.
• Habitual abode (gewoehnlicher Aufenthalt, s. 9 AO). You are resident if you stay in Germany for more than six months in a row. The six months can span two calendar years, and short trips away do not break the period.

Rules that can follow you after leaving

• Extended limited tax liability for 10 years (s. 2 AStG). German nationals resident at least 5 of the last 10 years who move to a low-tax country and keep substantial German economic interests stay taxable on a wider range of German income for 10 years after the year they leave.
• Inheritance and gift tax follows German nationals for 5 years. German nationals remain fully liable to German inheritance and gift tax for 5 years after leaving; s. 4 AStG can extend this to 10 years for moves to low-tax countries.

Exit tax in Germany

Wegzugsbesteuerung (s. 6 AStG) and fund units (s. 19(3) InvStG)

• Shareholding in a company of at least 1% at any time in the last 5 years (s. 17 EStG), held privately, wherever the company is.
• Unlimited German tax liability for at least 7 of the last 12 years before leaving (rule since 2022).
• Since 1 January 2025, also investment fund units held privately if you hold at least 1% of a fund or the fund units cost at least EUR 500,000 (tested per fund).

Deemed sale at market value. The gain on company shares is taxed under the partial income method: 60% of the gain is taxed at personal income tax rates (up to 45% plus solidarity surcharge).

Exit tax → · Am I still resident? →

Arriving in Italy

Personal income: €300k flat · Company tax: 24%

Opt into the new residents regime when you move.

Tax residency in Italy; not resident there in 9 of the last 10 years.

From 2026, €300,000 a year on foreign income (€50,000 per family member). Only pays off with income in the millions.