I've written extensively about Germany's exit tax before, but this time, I'd like to write about the #1 question people asked me afterwards: What did *I* do, i.e. how did I solve my German exit tax situation?

TLDR: I wanted to move to Thailand to live with my girlfriend. I own a few companies which means I'd be hit by the German exit tax. My exit tax bill would have been cost-prohibitive, so I couldn't leave the country (yes, seriously). I chose to incorporate a new GmbH & Co. KG company and moved all my holdings into it. All future company-related earnings are now taxed in Germany (which is fine). It was very difficult to arrive at this setup: It took me 1.5 years and required calls with 13 tax advisors. I spent 18.7k€ in tax advisor and notary fees in total, which probably is on the lower end of what people in similar situations need to spend. Germany has a very entrenched Shady Tax-Advisor-and-Notary Industrial Complex (STANIC).

There you have it. Thanks for listening to my ted talk on German exit tax, chuckle. Or, read on for the details. If you're a business owner, who knows, maybe some day you might want to do something crazy, like.. actually be able to leave the country. So it might make sense to learn about German exit tax now. 

First off, a short message to those I call "the people with the pitchforks". It has been my experience that many people, maybe even a majority, are actually in favor of the German exit tax. Usually these people are not affected by the exit tax themselves. Their reasoning is "how dare you create jobs in Germany and use German infrastructure (fax machines etc.) to build your company, and how dare you leave now!".

To those people, I have a reassuring message: My companies continue to pay German taxes, there is no loss to the German taxpayer. This post is not about optimizing, reducing or evading taxes.
 
This post is about me being able to leave the country.

And it just took me 1.5 years, 13 tax advisors and 18.7k€ to actually do so.

This is one of the few actual case-study write-ups out there (maybe the only one?), so I think this could be genuinely useful for many people. Especially those people who prefer to do their own research instead of paying the Shady Tax-Advisor-Notary Industrial Complex (STANIC) to do so.

My girlfriend and I tried living both in Germany and in Thailand. We liked Thailand more, and decided to move there. I had been living in Germany and owned multiple companies, most notably my holding company which owns OpenRegulatory. This means I would be hit by the German exit tax as soon as I would leave the country, i.e. by giving up my Berlin flat and moving to another country.

The German exit tax is very.. expensive. In simplified terms, I'd have to simulate a sale of all my companies at a high valuation (13.75 * earnings), and pay 30% tax on that. Or, multiplied and simplified, my company's earnings multiplied by 4.125 (13.75 * 0.3).

Example: Your company is making 200k€ profit per year. This is not a huge number. If you leave Germany, your exit tax would be 825k€ (4.125 * 200k€). This is a huge number.

So, unless you have 825k€ cash lying around, you can't leave the country. Cool, huh?
 
Now, in the unlikely case in which you do have 825k€ cash lying around, you are still subject to the tax office changing its mind. Yes - they can come back to you and ask for more. They might have looked at your company 1-2 years later (!) and decided that its valuation and therefore your exit tax should be higher. This is not a theoretical scenario - it happened to Christian Wolf, a semi-famous German founder who moved to Cyprus and paid millions in exit tax (before the tax office asked for more), who recounts his experiences with the German tax office on YouTube.

(As a side note, if you've raised VC, the tax office will likely take your inflated VC valuation instead of the earnings valuation above. This is the worst-case scenario: High valuation, high exit tax, low liquidity. Good luck raising YC and trying to leave Germany - you can't.)

Back to my situation. I'll have to keep things a bit generic as I don't want to divulge too many personal details here, but let me just tell you that I did not have six-figure sums of cash lying around, especially given the ambiguity of the calculation (would it be 100k€ or 1M€?). Therefore the German exit tax looked like it would be cost-prohibitive for me.

So at this point, I was not able to leave the country, where "leaving the country" is defined as "moving somewhere else". It feels rather weird saying that while living in a free, democratic country.

But of course there are solutions.. right? Right. "Just talk to a tax advisor", famous last words.

I don't know what my former self would have thought when "talking to tax advisor" would actually result in me talking to 13 tax advisors for 1.5 years, but here we are. Enter the what I call Shady Tax-Advisor-Notary Industrial Complex (STANIC).

Germany doesn't have a lot of corruption - for example, people trust the police, and people trust the bureaucrats in various administrative branches of government.

And even if you'd want to attempt to bribe someone, say, someone at the company registry to register your newly-founded company faster than the usual 1-3 months, you wouldn't succeed for the simple reason that you wouldn't be able to reach anyone there. Emails are not responded to, and call hours are limited to absurd time slots (e.g. only Tuesdays 10:00 - 12:00). Your last resort might be to send them a fax in which you offer your bribe. But even if someone would read it, they'd likely think this was a joke.

In all seriousness, bribes are not a thing in Germany, and that's a good thing!

Well, those are bribes. What about corruption? What even is the definition of corruption? If you widen the definition to "having to spend money on useless middlemen who act as gatekeepers", Germany suddenly suddenly feels very different.

You'll notice that, as soon as you have to get anything done in Germany which goes beyond being a German Salaryman, there is suddenly a large number of people wearing suits and sporting degrees in Very Regulated Professions whose services you suddenly have to pay for. They sit in nice offices, offer you coffee, and send you PDF invoices compliant with Germany's newest e-invoicing data format.

I'm of course talking about the lawyers, tax advisors and notaries - or, what I call the Shady Tax-Advisor-Notary Industrial Complex (STANIC) which seems to have an invisible, firm grip on the German society (and economy).

Want to purchase a house or a condo? Can only be done at a notary whose main service is reading the contract out loud to you, while charging a (significant) fraction of the sale price.

Want to found and run a company? Can only be done with a tax advisor who charges you 3-6k€ (minimum) for yearly bookkeeping fees.

Want to leave the country? Hah, here we are. This apparently costs you 18.7k€ (n=1), payable to the STANIC, minimum, as I did a lot of research myself.

The biggest problem with the STANIC is that it's very intransparent. Google Maps reviews are not helpful as many tax advisors manipulate them by removing negative reviews. The only thing which worked for me in the past was to rely on personal recommendations, but I didn't have anyone in my network who had actually done this German exit tax before.

So I was left with brute-forcing this problem. I decided to simply reach out to all exit tax advisors I found on the internet, 13 in total.

Oh man, where to start - there are so many stories here. They all can be summarized as "this industry is shady as hell". Some anonymized examples:

It is hard to overstate how shady this industry is.

I'd sometimes love to show those politicians who thought "yes, the German exit tax is a great idea, and it's transparent and easy to implement" which second-order effects their decision actually had in the real world. You literally have spawned hundreds (thousands?) of shady people in useless professions who gate-keep information and over-bill their clients. It's truly unbelievable. And it doesn't seem to be getting any better - the tendency in Germany seems to be to introduce even more regulated, gate-keeper, mandated professions.

And talking about simplicity - the German exit tax is not simple.

Can't you just pay it and be done? Yes, in theory.

But to quote Big Company Dude: "I used to work at the tax office, and the funny thing was that we never actually saw anyone file to pay the exit tax". Yeah, very funny, Big Company Dude.

It turns out that there are more than 10 different solutions for the German exit tax, each of them with different tribal knowledge guarded by a small number of select members of the STANIC, and it's entirely unclear which of these solutions might work in any particular situation. Almost all of those solutions result in actually not paying any exit tax, but instead paying an "implicit exit tax" to the STANIC.

That's what I did. At 18.7k€, I still got a rather good deal, I think. But, again, note that I paid this for the sole privilege of being able to leave the country and continue to pay German taxes with my companies.

And, for that, I talked to 13 of them, spent 1.5 years of my life on this and paid 18.7k€.

Anyway, I think I've mapped out the space pretty well now. Here are all solutions I found:

As you might expect, I chose the KG holding solution, and successfully moved to Thailand in March 2026. This means that my German exit tax bill is 0€, but that all my future company-related earnings, including profits, dividends and appreciation in value are taxed in Germany. A tremendously good deal for the German tax office, by the way, due to the inclusion of appreciation being taxed in Germany; note that if I had "just" paid the exit tax (nervous chuckle), future appreciation would not be taxed in Germany. So the KG holding solution is, all things considered, the best deal for the tax office.

Here's an overview over all my steps and their cost:

The GmbH & Co. KG is one of the most complicated German ways to incorporate a company, and that is saying a lot as the less-complicated "normal" GmbH already involves 3 months and 16 steps. Suffice to say, this is the boss level of bureaucracy in a country which already offering bureaucracy on hard mode.

If all things go well, you can be done in 4 months. If all things don't go well, you can not be done in 12 months.

One thing is worth repeating: You're doing all of this for the "privilege" for your companies to continue paying taxes in Germany, and likewise for the "privilege" of being able to leave the country.

1. Founding the GmbH & Co. KG: 3 months, 16 steps
This is a pretty "normal" founding procedure of a German company, i.e. 16 steps and 3 months. You also need to go to a member of the STANIC, specifically a notary, and pay them for reading out the incorporation documents (which you wrote) to you and adding it to the company registry.

(Optional side quest: Found a second new GmbH which becomes the "Komplementär-GmbH" for the GmbH & Co. KG in case you don't have a suitable GmbH lying around. This adds another 3 months and another 16 steps.)

I had the questionable pleasure of getting audited by the transparency registry upon founding, which added another 3 months to the timeline. This made zero sense because it was an empty company, 100% owned by me. So there was quite literally nothing to audit. The transparency registry also noticed this, but it took them 3 months to do so.

Next up, the tax office took another 3 months to issue the company's tax ID. Luckily, this could happen in parallel to the transparency registry pretending to audit my empty company.

The people at the tax office were reachable by phone, and they were very nice, always offering different explanations on why my tax number hadn't been issued yet. My favorite explanation was that the employee I was talking to was currently working from home because she was sick, and that my physical company documents were in the tax office, so she couldn't go there and fetch them to work on them because then she'd be transmitting her disease to her colleagues. The next day, I talked to her colleague at the office who said that the physical documents weren't there and that her coworker had likely taken them home with her as she was working from home because she was sick.. so Schrödinger's cat is real, at least at the German tax office: Your physical documents can be in two places at the same time, but they're always at the place where they currently can't be worked on. You can't make these things up.

All of this, i.e. notary, company registry etc., costs around 1k€, just to incorporate an empty company. I also forgot that another useless middleman shows up to send you an invoice - the IHK, the chamber of commerce, universally hated by all entrepreneurs in Germany because you can't opt out of their "membership" which costs a minimum fee of 300€ / year, based on your revenue. The median German business uses the IHK services zero times. A great honorary member of the STANIC.

2. Moving companies into the GmbH & Co. KG
You can move existing companies into a GmbH & Co. KG in a tax-neutral way. This makes sense, because the KG is tax-transparent, so you continue to pay taxes on dividends etc. of those companies, but now through your new GmbH & Co. KG.

A simplified explanation which I like to use is that "The GmbH & Co. KG stays in Germany instead of you, and continues to pay taxes instead of you". In theory, an elegant and fair solution for the German exit tax.

In practice, you'll again need a notary for this.

Here's where it gets hilarious. Apparently, moving companies into a KG is not something which happens often, so the notary which I chose and ended up paying 2k€ (!!) for this quite literally didn't have a document template for this.

She attempted to draft something, but that something was so far from what I wanted that I told her that I'd ask a tax advisor for a template instead.

But it gets more crazy!

So one of my 13 tax advisor did indeed have a template, I offered to pay them for said template, and they said for that I'd have to become their client for them to send me this template, and the minimum payment to become a client would be a one-off 1.9k€.

Okay, so 1.9k€ for a Word template. No big deal, right, this industry is transparent, great, and not shady, I feel like I'm having a great experience as a customer here.

Luckily, I had a choice! The notary kindly also introduced me to another tax advisor. This tax advisor didn't have a template, but noted that he was not sure whether this whole setup worked at all, and he kindly offered to analyze this whole setup for for me for the great price of 5-8k€. Remember that I had already double-checked this setup with (counts fingers) 13 tax advisors, I think it's fair to assume that this concept was vetted a bit beforehand.

I just needed the damn template.

Now, faced with the choice between "paying 1.9k€ for a tax advisor to send me a Word template" and "paying 5-8k€ for a tax advisor to not send me a Word template and question the entire concept", I chose the 1.9k€, this suddenly sounded like a real bargain.

The silver lining was that I could use the remainder of the 1.9k€ for consulting hours with the tax advisor. No clue how many made-up hours they deducted for sending me the Word template though.

(The big irony here is that my company OpenRegulatory became famous on the premise of offering free templates for medical device compliance. Maybe, one day, I'll launch another company with free templates for exit tax compliance.)

1.9k€ spent and Word template in hand, I went back to the notary to move my company shares into my new GmbH & Co. KG. This worked - surprisingly so, because with notaries there's always the residual risk that they think they have to provide any sort of random additional services to you to justify their ridiculous fees, so a notary might simply not accept your template and insist on drafting something themselves.

After the notary appointment, you have to wait for the company registry to actually update the ownership of your companies from you to the GmbH & Co. KG.

Pop quiz: Can you leave Germany now? It's actually a legal gray area. Sure, you've done the notary appointment, but which date is the relevant one for "transfer of ownership of your companies"?

Turns out, no one knows! Cool.

So better stay safe and wait for the company registry to update. This takes another 2-6 months, depending on how slow it is.

The notary appointment cost 2k€. This included the service of reading out the template to me, which I had purchased from a tax advisor for 1.9k€, because the notary, who I paid 2k€ for this appointment, didn't have one.

3. Move more companies into the GmbH & Co. KG
One thing to note is that you only need a notary appointment for moving German companies into your new GmbH & Co. KG. If you were moving foreign companies into there (which are also covered by German exit tax - cool!), those don't require a German notary.

That's cool, so simple, right?

One massive unexpected problem which could in theory ("in theory") hit you is that your tax advisor, who is currently handling your GmbH & Co. KG, might want another tax advisor to write an assessment on each foreign company you might want to move into the KG. This has no rational reason besides tax advisors being 1) risk-averse, 2) happy to charge you money and 3) being very happy to refer you to other tax advisors who are also risk-averse and happy to charge you money.
 
I call this the "tax advisor inception graph":

This "tax advisor inception graph" could of course be flattened to simply "tax advisor A does X", but that doesn't seem to be in anyone's interest here (besides yours, of course, but that doesn't count).

Such an assessment can cost another 5-10k€, and is typically a 20-page Word document. Ask me how I know. Again, I think this is the lower end of the pricing range.

4. Maintenance tasks
Your GmbH & Co. KG also needs to actually have an operational business in Germany, i.e. it can't be just a holding company. Bullet points:

In isolation, all of these tasks would be rather complicated and difficult. But, in contrast to the preceding tasks (asking 13 tax advisors for a Word document you end up paying 1.9k€ for, waiting for the transparency registry to not-audit your company, etc.), all of these tasks actually sound really easy now.

For example, physical office spaces can indeed be rented by asking around, and the rest I'll leave up to your bureaucratic creativity, you'll figure it out.

More quiz questions for you:

So yeah. Changing a company's managing directory and address costs 1.5k€.

It amuses me when German politicians publicly wonder why all German entrepreneurs are leaving the country. Maybe because the German bureaucracy treats them like crap and expels them, like an immune system fighting an invader? Germany's immune system certainly doesn't want entrepreneurs right now.

Alright, that's it. I hope this answers your question on how I solved my exit tax.

Reach out to me via the contact form if you have any questions, or leave a comment below!