Start with the decision you are making
Germany can be a place to live, employ a team, serve customers or hold a long-term business presence. Those objectives call for different structures. Choosing a German company is not the same decision as moving its owner, and a foreign company can still acquire German tax obligations through the way it is run.
For an owner already in Germany, the first question is what will actually change: the owner’s home, the location of staff, management authority, customer contracts or ownership. For an incoming family, connect the immigration route with the dates on which tax residence and work begin.
Find the relevant guide
| Your question | Start here |
|---|---|
| What happens to my income and investments? | Personal tax guide: residence, rates, gains, foreign companies and departure |
| How is my company taxed? | Corporate tax guide: management, national and local tax, CFC rules and withholding |
| Can our family live and work here? | Relocation guide and EU Blue Card programme |
| What changes when I leave? | Departure guide: homes, unsold shares, fund holdings and continuing German income |
| Could I become a citizen? | Citizenship guide: descent, ordinary naturalisation, marriage and current dual-nationality rules |
| How do we get financially operational? | Banking guide and Berlin practical guide |
Three common planning situations
A founder moves to Berlin but continues to approve contracts and direct a foreign company. Both personal residence and the company’s management must be reviewed; leaving the company register abroad does not settle either.
An established German owner opens a genuinely staffed foreign operation. The structure needs commercial allocation of work, pricing and authority, together with CFC and permanent-establishment analysis. The tax treatment follows more than the incorporation certificate.
An investor leaves Germany holding a business stake and a large fund portfolio. Residence cessation, treaty rights and the distinct share/fund exit provisions must be assessed before the move, while the destination’s arrival treatment is still being planned.
Plan the implementation as well as the answer
A useful engagement should identify the sequence, people responsible, evidence needed and ongoing work. Immigration permission, local formal tax advice, company changes, banking and recurring filings should have clear owners. We can help assess how the cross-border pieces fit and define the implementation scope for the actual situation; no country-specific provider arrangement is assumed by this guide.
Sources & research notes9 references
Sources supporting this guide. Research draft awaiting editorial review.
- Fiscal Code §8: dwelling-based residence
- Corporation Tax Act: residence, participation and exit provisions
- Federal skilled-immigration portal: EU Blue Card
- Income Tax Act: current consolidated law
- Nationality Act: current consolidated law, including July 2026 amendment
- Fiscal Code: management, permanent establishment and procedure
- Foreign Tax Act §7: controlled foreign entities
- Foreign Tax Act §6: shareholder exit tax
- Investment Tax Act §19: fund disposals and departure