Management & permanent establishment
Actual central management and fixed business facilities can create German tax exposure; a foreign registered address is not sufficient.
Sections 10 / 12 AO ↗
Residence & Relocation
Greece · Non-Dom
Plan residence and investment together, with separate eligibility and asset assessments.
Where it fits
The location must fit the plan.
For qualifying new tax residents able to meet the personal and investment conditions.
Scope
From context to execution.
- Review of ownership, activity, residence and countries involved.
- Agreed responsibilities, document checklist and open specialist questions.
- Coordination of company or residence documents, banking preparation and local professionals within the agreed scope.
- Document handover and a schedule of ongoing obligations.
Article 5A generally provides annual substitute taxation of EUR 100,000 on included foreign income. As of 09/2026.
A qualifying investment generally starts at EUR 500,000, subject to categories, deadlines and exceptions. As of 09/2026.
The regime can generally run for up to 15 years. Greek-source income remains separate. As of 09/2026.
Requirements & Substance
What needs to be clear first.
Prepare residence history, actual relocation and investment evidence. Property also needs title, cost and liquidity review.
Timing
A sequence with clear dependencies.
Document review, specialist clearance, filing and account or status decisions follow separate processes. Once the documentation and scope are clear, we agree a schedule. Authority and bank decisions cannot be guaranteed.
Ongoing Duties & Cost Drivers
The structure must work day to day.
Annual payment, filings and investment evidence require ongoing management. Immigration permission does not itself establish tax residence.
German connections
From a German perspective.
Preferential taxation and remaining German interests may trigger section 2 AStG where all conditions are met. Review exit tax and treaty residence before applying.
Controlled foreign companies
Control, income type and actual taxation matter. The low-tax threshold is below 15% (as of 09/2026); EU/EEA substance rules require evidence.
Sections 7–13 AStG ↗Foreign-interest reporting
Foreign businesses and shareholdings may trigger notification duties. Conditions, thresholds and deadlines need review.
Section 138(2) AO ↗Exit taxation
Departure or restrictions on German taxing rights can trigger taxation of unrealised gains on covered interests, subject to personal conditions.
Section 6 AStG ↗Remaining German interests
German nationals meeting all relevant conditions may face extended limited taxation for up to 10 years after the departure year (as of 09/2026). Preferential taxation alone is insufficient.
Section 2 AStG ↗Tax treaties
Residence, income, entitlement and the current treaty text determine relief. The existence of a treaty is not a blanket exemption.
Treaty status ↗This overview does not replace case-specific review by directly appointed, qualified legal and tax professionals.
Read on
Guides and terms for this country.
Residence21 September 202616 min
Exit tax: how to plan your move with a GmbH shareholding
Exit tax slows down entrepreneurs who want to move, but it can be planned well and in many cases avoided altogether. This article explains who it concerns, how the value is determined, how to pay in seven interest-free instalments or be released entirely under the return rule, works through a move to Cyprus and sets out the sequence in six steps.
Read the articleResidence21 September 202616 min
Extended limited tax liability: how to put your German interests in order before the move
Non-dom in Cyprus, flat tax in Italy or a country without income tax: whether the German special rule applies depends above all on your economic interests in Germany. This article explains the thresholds in plain language, compares two moves to Cyprus and shows how to plan freely with the US LLC or a company at your new home.
Read the articleResidence21 September 202616 min
Avoiding German exit tax: how the right structure before the move eliminates or reduces it
Exit tax is an obstacle to mobility, but not a fate. Only what you hold as private shares on the day you leave is taxed. This article shows how to change the structure before the move so that the tax does not arise, what each route requires, and how to reduce it with valuation reports and instalments where avoidance does not fit.
Read the article
Questions & Answers
Worth knowing.
Does any investment qualify?
No. Categories and evidence requirements apply.
Does a residence permit replace the tax application?
No. The procedures are separate.
Is Greek income included?
Not simply through the foreign-income regime.
Is asset review part of the project?
Yes. Economic and legal reviews are coordinated.
Does Germany remain relevant?
Yes. Departure and remaining connections need separate assessment.