Anyone moving abroad wants a clean break with the German tax office. That works well once you know what matters. Deregistering at the registration office is just a form. For tax purposes, what counts is where you live and where you stay. Both are in your own hands.
This article shows how to move your residence so that unlimited tax liability in Germany ends. It applies to a move to a new country of residence just as much as to entrepreneurs who live and work location-independently.
What matters: home and presence
Germany taxes your worldwide income as long as you have a residence or your habitual abode here (section 1 EStG). Both are matters of fact. Deregistration is a duty under registration law and good evidence, but it is not the switch itself.
That is good news. You do not have to convince anyone; you only have to create facts: give up the home, move your presence, collect records. Unlimited tax liability then ends on your moving day.
In short: for tax purposes home and presence count, and you shape both yourself.
Your German home: give it up, sell it or let it
You have a residence where you hold a dwelling that you are likely to keep and use (section 8 AO). A furnished room or a holiday flat is enough. There is no fixed minimum number of days.
There are three clear routes for the move:
- Terminate the lease if you rent. Take the furniture or store it, hand back the keys.
- Sell if you no longer need the property.
- Let long-term if you keep the property as an investment. Unlimited term, to unrelated tenants, without your own key or your own room.
German rental income then remains taxable in Germany. That is normal and does not change the fact that you yourself have left.
In short: without a dwelling at your own disposal, you have no residence in Germany.
Visits to Germany: easy to plan
You have a habitual abode where you stay other than merely temporarily. More than six months in a row always counts as a habitual abode (section 9 AO). That is where the well-known 183-day rule comes from. The only exception is a stay purely for visits, recreation or a cure lasting no more than a year.
Visits to family and friends, trade fairs and client meetings naturally remain possible. What matters is that Germany does not again become the place where you regularly live and work. Three simple habits help:
- Stay in a hotel or with hosts when visiting, without a room of your own.
- Keep visits reasonable and run your business from your new home base.
- Note your travel days in a simple spreadsheet or app.
In short: visits are no issue as long as your daily life and work happen abroad.
New residence or location-independent living
Most readers move to a new country of residence, such as Cyprus, Bulgaria or the United Arab Emirates. There you become tax-resident and can obtain a certificate of residence. With it you use that state’s double taxation treaties.
If two states regard you as resident at the same time, the treaty decides in a fixed order: first the permanent home, then the centre of vital interests (Article 4 OECD Model). Once you have given up your German home, you are clearly at home in the new country (Using double taxation treaties).
Living without a fixed residence is just as recognised. A perpetual traveller who travels permanently and works on the move has neither a home nor a habitual abode in Germany and no longer has unlimited tax liability here. He runs his company from wherever he is. The US LLC is the right structure for this model. German nationals who keep larger economic interests in Germany put these in order beforehand (Extended limited tax liability).
In short: whether a new country of residence or location-independent, both end tax liability in Germany.
A folder that documents your move
If the tax office asks, records count. Start a folder from day one, digital or on paper:
- termination, sale contract or lease for the German home,
- lease or purchase contract at the new place,
- deregistration and registration in the destination country,
- travel-day spreadsheet,
- address changes for insurance, phone contract and bank,
- certificate of residence from the new state, where available.
This takes little time and makes your move traceable for any third party.
In short: a well-kept folder documents your move in a few minutes.
Cyprus and the 60-day rule
Alongside the 183-day rule, Cyprus offers a 60-day rule. With it you become resident after just 60 days a year in Cyprus. You need a home and an activity in Cyprus, may not stay in any other state for more than 183 days and may not be resident there (as of 09/2026, Cyprus country page).
The rule suits entrepreneurs who travel a lot and still want a fixed state of residence. Your German home has been given up for this, otherwise you would still be resident in Germany.
In short: after leaving Germany, the 60-day rule is a flexible solution for frequent travellers.
Austria and Switzerland
Austria defines residence and habitual abode almost like Germany (section 26 BAO). If you give up your home and move your presence, unlimited tax liability ends there too.
In Switzerland, your tax domicile is where you stay with the intention of remaining permanently. For a stay without domicile, lower day thresholds than 183 days apply. A Swiss fiduciary adviser clarifies leaving Switzerland and cantonal rules.
In short: in Austria and Switzerland too, you end tax liability through home and presence.
Our recommendation
Treat leaving as a project with four steps:
- Settle your new base: a country of residence or deliberately location-independent.
- Terminate, sell or let your German home long-term.
- Move, deregister and start the records folder.
- Set up the company for your business to fit your way of life.
For location-independent entrepreneurs we recommend the US LLC from €1,800. It fits especially well without a fixed tax residence or with residence in a country without income tax on this income (USA country page). The steps around deregistration are collected in the “Leaving Germany” checklist.
If you move within the EU: move your residence first, then incorporate. The residence models are listed under /residency, such as Cyprus with non-dom status, Italy or Greece with a flat tax and Bulgaria with 10% income tax (as of 09/2026). In Cyprus you then form a Ltd from €4,500 (Cyprus country page). GCS plans the move with you, forms the company and coordinates the tax advisers in both countries; a first conversation is where it starts.