Application process & timeline
An exit project includes later evidence and transaction monitoring, not only the moving date.
01Confirm residence and treaty factsBefore departure
Assess retained homes, family and business connections.
02Inventory and value assetsBefore rights change
Reconcile historic and arrival costs, portfolio transfers and departure values.
Documents & evidence
- Acquisition records
- Prior Austrian assessments
- Valuations
03Set the treatment and notificationsRelevant departure return and custodian deadlines
04Review the 2026 transitionBefore 31 December 2026 for covered historic cases
Check old non-assessed debts against the enacted transition rather than the current account balance.
Start with taxing rights, not the registration form
Austrian residence can continue through an available home even after a person deregisters or starts spending more time abroad. A treaty may allocate residence differently, but that requires the actual facts and the applicable text. Prepare a dated record of homes, family, work and the intended destination.
For each asset, ask whether the move restricts Austria’s taxing rights. That question matters more than whether an Austrian broker continues to hold it. A change of treaty position or a transfer can have effects even where no asset is sold for cash.
Value the right assets and retain the history
Covered capital assets, derivatives and crypto require review under §27. Retain original acquisition records, any market-value basis established on arrival, later adjustments and departure valuations. A custody statement showing current market value is not necessarily evidence of the correct tax cost.
A return mover may be subject to the special re-entry rule for an earlier Austrian non-assessed departure. Check the old decision before assuming the portfolio receives a second market-value reset. The destination may also use a different arrival basis, creating a mismatch that should be considered before a sale.
EU/EEA non-assessment is conditional
For qualifying individual moves into the EU/EEA, the liability can be addressed in the assessment while not being assessed for collection until a later triggering event, on application. This is not an exemption or an automatic consequence of choosing an EU address.
Later disposal, onward departure outside the relevant area and other statutory events require review. Notify the custodian consistently and retain correspondence supporting any applicable withholding treatment. A transfer between depots may need its own notification to avoid a deemed disposal.
Check the new annual and transitional evidence duties
For relevant decisions after 30 June 2026 and computed gains exceeding €100,000, current §27 adds annual proof that a triggering event has not occurred. The evidence is due by the end of the following year and must include a current address. A deficient submission can require correction; failure can have assessment consequences.
The 2026 amendment also looks backwards. Certain tax debts arising after 31 December 2005 and addressed in decisions before 1 July 2026, which remain not fully assessed and exceed the statutory amount test, require evidence by 31 December 2026. Have the historic decisions reviewed instead of assuming an old move is outside the new rules.
Keep the company and remaining income on separate tracks
An Austrian company does not cease being Austrian merely because its shareholder leaves. Conversely, transferring management or business assets may create its own tax consequences. List who will make decisions and where employees, contracts and assets remain.
After departure, Austrian-source dividends, property or work can remain relevant. Confirm treaty relief, tax correspondence and any continuing return requirements. Keep the evidence owner and filing calendar explicit; overseas residence can make missed notices harder to resolve.
Sources & research notes7 references
Sources supporting this guide. Research draft awaiting editorial review.
- BMF: personal tax residence and worldwide income
- EStG §27: current arrival, exit and portfolio-transfer rules
- BGBl I 43/2026: exit-proof duties and transition
- BMF: capital gains, exit and custody transfers
- Income Tax Act: consolidated September 2026
- USP: company seat, management and worldwide tax liability
- BMF: nonresident withholding and refund categories
