Moving abroad changes your tax life more than any deduction ever will. Done well, it’s the biggest legal lever there is. Done sloppily, you end up paying in two countries – or in the old one only, with a nice view of the new one.
This guide walks through what happens to your taxes when you move: when the old country lets go, when the new one takes over, what the old country keeps taxing and which newcomer regimes are worth planning around. We use Germany as the main example because its rules are strict and well documented; the logic applies almost everywhere. General information as of September 2026, not tax or legal advice.
The three questions every move raises#
Every international move boils down to three questions, and you need an answer to all of them:
- When does my old country stop taxing my worldwide income? Usually when you give up your home and habitual abode there.
- When does my new country start? When you meet its residency test.
- What does my old country keep taxing anyway? Income sourced there, exit taxes on the way out and sometimes extended rules for years.
Get one wrong and the other two don’t matter. The classic mistake is to answer only the second: “I live in Dubai now” – while the old flat in Hamburg is still furnished and waiting.
Leaving: when your old country lets go#
Most countries tax residents on worldwide income and non-residents only on local income. So the switch from “resident” to “non-resident” is where the money is.
In Germany, you’re fully taxable as long as you have either:
- A home (§8 AO) – a flat you can use whenever you like, owned or rented, even if you’re there 20 nights a year, or
- A habitual abode (§9 AO) – a stay of more than six months, even across two calendar years.
Deregistering (Abmeldung) is necessary but not sufficient. The tax office looks at facts: is the flat sold, let long-term or given up? Is your family still there? Our leaving Germany guide has the full step-by-step exit and a 12-month timeline.
Austria and Switzerland work similarly: a home or a longer stay keeps you resident. The Netherlands, Spain and others look at your “centre of interests” – where your family and economic life are. The detailed tests are in our tax residency guide.
Arriving: when your new country takes over#
Your new country applies its own test. The common ones:
- 183 days in the tax year – still the default in many countries.
- A home or centre of life there, sometimes with far fewer days.
- Special short routes: Cyprus with 60 days (plus a Cypriot home, business, job or directorship, no other tax residency and under 183 days anywhere else), or the UAE with 90 days for residence-visa holders with a home or business there.
Ask for a tax residency certificate as soon as you qualify, and every year after. It’s what banks, treaty claims and your old tax office want to see. Count your days with the day tracker.
If two countries both claim you, the double tax treaty’s tie-breaker decides: permanent home, then centre of vital interests, then habitual abode, then nationality. Without a treaty there’s no tie-breaker – and Germany has had no treaty with the UAE since the end of 2021.
Newcomer regimes worth planning around#
Many countries compete for mobile people with special regimes. As of September 2026, the ones we see most:
| Country | Regime | What it does | Catch |
|---|---|---|---|
| UAE | No personal income tax | 0% on salary, dividends and capital gains | You really have to live there; no treaty with Germany |
| Cyprus | Non-dom | No Special Defence Contribution on dividends and interest for 17 years | 2.65% health contribution; company tax 15% |
| Malta | Remittance basis / Global Residence Programme | Foreign income taxed only when brought to Malta; GRP 15% flat | €5,000 minimum once foreign income exceeds €35,000; GRP minimum €15,000 |
| Portugal | IFICI (“NHR 2.0”) | 20% flat on qualifying work income, most foreign income exempt, 10 years | Only qualifying professions and activities |
| Spain | Beckham regime | 24% flat on work income up to €600,000, six tax years | No Spanish residence in the previous five years |
| Italy | Flat tax / impatriates | €300,000 a year covers all foreign income (moves from 2026); or 50% of work income exempt | The flat tax suits only large foreign incomes |
| Greece | 5A / 5B / 5C | €100,000 lump sum on foreign income; 7% for pensioners; 50% exemption for newcomers’ work income | 5A needs a €500,000 investment |
| United Kingdom | 4-year FIG regime | Foreign income and gains exempt for four years after ten years abroad | Non-dom status is gone since April 2025 |
| Switzerland | Lump-sum taxation | Taxed on living costs, not income | No Swiss work allowed; federal minimum base CHF 435,000 |
Which one fits depends on how you earn. Company owners usually look at the UAE, Cyprus and Malta; employees and freelancers at Portugal, Spain and Italy. The Nerdy Index ranking compares all of them (methodology), and the Jurisdiction Finder shortlists them for your profile.
The year you move#
In the year of the move you’re usually resident in the old country until the move and in the new one afterwards. In Germany that means unlimited tax liability until the day you leave and limited liability afterwards, in a single return. Foreign income from the rest of the year can still raise your German rate through the progression clause.
Some countries (like the UK with its split-year treatment) have formal rules for this; others simply apply their day test to the whole year. Timing the move – say, early in the year versus late – can change which country taxes a big bonus or a dividend. Plan it.
Exit taxes: the bill for leaving#
Several countries tax gains you haven’t realized yet when you move away. The most relevant for our readers:
- Germany (§6 AStG). If you hold 1% or more of a corporation and were resident for at least seven of the last twelve years, Germany taxes the unrealized gain on your shares as if you’d sold them. Since 2022 there’s no more open-ended deferral for EU moves; you can pay in seven annual instalments, usually against security. Since 2025 the exit tax also covers large investment fund holdings (acquisition cost of €500,000 or more, or 1% of a fund). Full breakdown in the German exit tax guide – with a worked example where a €1 million gain costs about €264,000.
- Austria, France, Spain, the Netherlands, Norway, Canada and others have their own versions, with different thresholds and deferral options.
- The US taxes citizens wherever they live; giving up citizenship can trigger an expatriation tax for “covered expatriates”.
Exit tax is the one item where planning after the move is almost worthless. Value, restructure or sell before you leave.
What your old country keeps taxing#
Leaving ends worldwide taxation, not all taxation. Germany keeps taxing non-residents on German-source income (limited tax liability), for example:
- Rent from German property – taxable in Germany; treaties leave that right with the country where the property is.
- German pensions – statutory pensions paid abroad are often taxable in Germany, depending on the treaty; a central tax office in Neubrandenburg handles most pensioners abroad.
- Dividends from German companies – withholding tax of 26.375% at source, which a treaty may partly refund.
- Work physically done in Germany – days you work there can be taxable there.
- Director fees from a German company – often taxable in Germany under the treaty.
On top of that come two German specials:
- Extended limited tax liability (§2 AStG). German citizens who move to a low-tax country (or to none) while keeping substantial economic interests in Germany can be taxed on more than normal German-source income for the year of departure and ten years after.
- Inheritance and gift tax. German citizens stay within unlimited German inheritance and gift tax for five years after leaving – longer in some cases.
Beyond income tax#
Taxes aren’t the only system that notices you’ve left:
- Social security. Inside the EU, you’re insured where you work; an A1 certificate proves it. Outside the EU, bilateral agreements decide.
- Health insurance. German public insurance generally ends when you move outside the EU. Private insurers often offer a cheap placeholder policy (Anwartschaftsversicherung) to keep your way back open.
- Banks. Tell your banks your new tax residency. Under CRS they’ll report your accounts to your new country. Some German brokers don’t serve clients in certain countries. More in banking abroad.
- Your company. If you run a company, it has to move with you – or be managed by someone else. See setting up a company abroad and place of management.
- Your visa. Tax residency and immigration status are separate. See digital nomad visas.
Your moving-abroad tax plan#
From idea to clean move
Map your income and assets
Salary, business profits, dividends, rent, pensions, shares and funds. Each is taxed differently on the way out and after.
Pick the destination by income type
Company owner, employee, freelancer, investor or pensioner? The right newcomer regime depends on it.
Check exit costs
Exit tax on shares and funds, extended tax liability, what happens to your company.
Set up residency in the new country
Home, registration, residence permit, then the tax residency certificate.
Close residency in the old country
Flat sold, let or given up, deregistered, ties moved – before the day you leave.
File the year of the move properly
Split-year return in the old country, first return in the new one, and keep the evidence for years.
Moving abroad: taxes covered?
Tick them off – your progress is saved in this browser only.
No flat available to you in the old country, family arrangements clear.
Lease, bills, permit, day log and a tax residency certificate.
Shares of 1% or more and large fund holdings reviewed and valued.
Rent, pensions, dividends and director fees you’ll still declare at home.
If both countries could claim you, you know where the tie-breaker lands – and whether there’s a treaty at all.
Health cover, pension rights and your banks’ tax residency records sorted.
FAQ#
Do I still pay tax in Germany if I move abroad?
On worldwide income, not if you’ve given up your German home and habitual abode. On German-source income such as rent, some pensions and German dividends, yes. And if you move to a low-tax country while keeping substantial German interests, extended limited tax liability can apply for ten years.
Is deregistering (Abmeldung) enough to stop paying German tax?
No. Deregistration is evidence, not the test. If you keep a flat you can use, you stay fully taxable in Germany, even with very few days there. See leaving Germany.
Does the 183-day rule mean I’m tax-free if I stay under 183 days?
No. 183 days is one test among several. A home or your family can make you resident with far fewer days, and some countries use shorter periods. The tax residency guide explains the tests.
What is exit tax and who pays it?
A tax on unrealized gains when you move away. In Germany it hits people with 1% or more of a corporation who were resident for seven of the last twelve years, and since 2025 large fund holdings. It can be paid in seven instalments. Details: German exit tax.
Which country has the lowest taxes for people moving abroad?
For company owners the UAE (no personal income tax) and Cyprus (non-dom) are common picks; for employees Portugal’s IFICI and Spain’s Beckham law; for very wealthy people Italy’s flat tax or Swiss lump-sum taxation. The best one is the one where you’d actually live.
What happens to my German pension if I move abroad?
You keep your entitlements. Whether the pension is taxed in Germany or your new country depends on the treaty and the type of pension; statutory pensions are often taxed in Germany at least partly.
Planning a move and not sure what it does to your taxes? Take the Jurisdiction Finder, then map your exit and your new setup together in a strategy session. This guide is general information, not tax or legal advice.
Sources#
- §8 AO – home (Wohnsitz)
- §9 AO – habitual abode
- §49 EStG – German-source income of non-residents
- Foreign Tax Act (AStG) – §2 extended limited tax liability, §6 exit tax
- §19 InvStG – exit tax on investment fund units
- §2 ErbStG – inheritance and gift tax liability
- Federal Ministry of Finance – double tax treaties by country
- OECD Model Tax Convention (2017), Article 4
- Regulation (EC) No 883/2004 – social security coordination
- GOV.UK – tax on foreign income
- Cyprus Tax Department
- Portuguese Tax Authority (AT)
- Spanish Tax Agency (AEAT)
- IRS – expatriation tax
