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
Italy · New Residents
A relocation supported by a clear income analysis, comparing the special regime with ordinary taxation and departure-state consequences.
Where it fits
The location must fit the plan.
For eligible new residents with an appropriate income profile and a real home in Italy.
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.
Covered new arrivals from 2026 face an annual EUR 300,000 substitute tax on included foreign income. Arrival timing and transitional rules matter. As of 09/2026.
The option generally runs for up to 15 tax years, subject to eligibility and exclusions. As of 09/2026.
Italian-source and specified excluded income require separate treatment.
Requirements & Substance
What needs to be clear first.
Document prior residence, ownership, family circumstances and the actual Italian home. Review each major income source.
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 payments, filings, evidence and local professional support create ongoing commitments. Property transactions are separate decisions.
German connections
From a German perspective.
Preferential treatment may be relevant to German departure rules. Section 2 AStG requires all statutory conditions; ownership and remaining German interests need assessment.
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
Moving your residence properly: how to end your tax liability in Germany
Deregistration is just a form; the clean tax break comes from facts you create yourself. This article shows how to move your home and your presence, how visits to Germany remain possible, why life as a perpetual traveller is a recognised model too, and how Cyprus’s 60-day rule helps frequent travellers.
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 article
Terms in the glossary
- Exit tax (Wegzugsbesteuerung)
- Extended limited tax liability (erweiterte beschränkte Steuerpflicht)
- Tax residence (steuerliche Ansässigkeit)
- Tie-breaker rule
- Domicile (Wohnsitz, section 8 AO)
- Habitual abode (gewöhnlicher Aufenthalt)
- Flat tax for new residents (Italy)
- Deregistration of residence (Abmeldung)
Questions & Answers
Worth knowing.
Does it cover every income source?
No. Domestic and excluded income are treated separately.
Does the new amount apply to earlier arrivals?
Not automatically; transitional rules matter.
Is the regime permanent?
No. A statutory maximum duration applies.
Is a company required?
No. This is a personal tax residence regime.
Why review Germany?
Departure and remaining German interests can have independent consequences.