Bitcoin and the German Exit Tax: What Applies When You Move Abroad

The short answer first: if you hold Bitcoin privately and move away from Germany, the move itself triggers no tax on your capital gains. There is no deemed sale on the day you deregister and no taxation of unrealised gains on your wallet balance. The exit tax that so many emigrants warn about catches something other than crypto assets. The move can still become expensive if you overlook the four places where German tax law reaches you even after departure: the moment your tax residence genuinely ends, the one-year holding period that keeps running when you sell, the legal form of your crypto investment, and the question of what your tax office will learn automatically from the 2026 reporting year onwards. This article works through those points in order, under German law, with the statutory references you can put in front of your tax adviser if in doubt. Does the exit tax under Section 6 AStG apply to Bitcoin held privately? Exit taxation means the state treats an asset as if you had sold it on the day you left and taxes the increase in value, although not a single euro has reached you. That is a hard intervention, and it is precisely why the legislator drew the scope narrowly. Section 6 of the Foreign Transactions Tax Act attaches to shareholdings within the meaning of Section 17(1) sentence 1 EStG, meaning holdings in corporations from a stake of one percent upwards. Shares in a German GmbH fall under it, and so do equity blocks above that threshold. A Bitcoin, an Ether or a stablecoin in your own wallet is not a holding in a corporation. The wording of the provision leaves no room here, and that is why there is no German exit tax on directly held crypto assets in private hands. You can read the statute yourself if you want to: Section 6 AStG on the portal of the Federal Ministry of Justice. The distinction matters in both directions. Anyone holding their coins through their own GmbH is not safe merely because the underlying asset is crypto. In that case the GmbH share is the asset that triggers the exit tax, and the value of the coins inside it helps determine how much tax falls due. The structure is widespread among German investors, and it turns the outcome on its head. Readers interested in the motives behind such departures will find the reasons and the destination countries set out in our survey of why crypto investors emigrate. When does your unlimited tax liability end: residence under Section 8 AO and habitual abode under Section 9 AO The decisive question when you leave is not when you boarded the plane but when your unlimited tax liability ends.