When a German tax resident moves abroad, Germany triggers a deemed disposal on shareholdings exceeding 1% (Wegzugsteuer). The gain is calculated on departure and can be deferred if you move within the EU/EEA — meaning Cyprus as an EU member qualifies for instalment treatment.
Germany's CFC rules (Außensteuergesetz) can attribute income of a foreign company back to German shareholders if the company is in a low-tax jurisdiction and the shareholder holds more than 50%. Careful substance requirements in Cyprus can break CFC exposure.
German trade tax adds 14–17% on top of corporate income tax, bringing the effective rate to approximately 30%. Cyprus has no trade tax equivalent. The 15% flat CIT rate is final for most structures.
While the Soli has been largely phased out for most taxpayers, high earners still face it. More pressing is Germany's inheritance and gift tax with rates up to 50%. Cyprus has zero inheritance tax and zero wealth tax.
Model §6 AStG deemed disposal, confirm EU deferral eligibility, file German notification.
Incorporate Cyprus LTD, appoint local director, establish genuine office presence to rebut CFC arguments.
De-register from German municipality, terminate or restructure German company if applicable.
60-day or 183-day rule satisfied, TIC and non-dom status issued, Cyprus becomes sole tax residence.
Services for relocating founders
Start your relocation today. Our team handles the structure, compliance, and residency process end to end.
Free consultation · No obligation · Reply within 2 hours
Legal Disclaimer: This page is for general informational purposes only and does not constitute legal or tax advice. Tax laws change frequently. Always seek independent professional advice tailored to your specific circumstances before making relocation or tax planning decisions.