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Company · April 2026

Avoiding exit taxation: what entrepreneurs must know

The fictitious sale under sec. 6 AStG can get expensive. How to plan ahead instead of being surprised.

Company · April 2026 · approx. 4–6 min read

What happens

When relocating residence, German tax law assumes a fictitious sale of the shares (generally from 1% holding). Tax becomes due on the assumed increase in value – even though no real sale takes place.

How to structure it

“Avoid” is too broad, but the burden can often be structured or spread – via timing, structure and valuation. The key is to clarify the topic with tax experts before the move, not after.

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