Motives for moving from Germany are of the very widest variety. General tax conditions abroad may be the decisive factor. But moving from Germany does not necessarily mean an end to German tax liabilities. Both German tax law and the dual-taxation treaties concluded with individual countries preserve the German authorities’ right to levy taxes in a large number of ways.

Moreover, removal as such may trigger some very unpleasant consequences when it comes to tax. Thus if a person relocating abroad has shareholdings in limited-liability companies amounting to at least 1%, he will be treated as if he had sold this holding at its current value. In other words, he will be taxed on a fictional profit from sale. We have developed various schemes for avoiding such unpleasant consequences.

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