German Exit Tax & Golden Visas: Portugal, Greece or Malta as the Right Destination for §6 AStG Emigration 2026

What is the §6 AStG exit tax, and who has been affected since 2025?

The Foreign Tax Act has existed since 1972, but its reach was long limited: originally §6 AStG only caught shareholdings of at least 1 per cent in corporations (§17 EStG). ETF investors and fund holders were considered outside the scope, their accumulated paper gains remained tax-neutral upon leaving Germany.

The Annual Tax Act 2024 (Jahressteuergesetz 2024) changed this fundamentally. Since 1 January 2025, units in investment funds under §§18 and 19 InvStG are also subject to exit taxation. The legislator justified this by reference to the economic comparability with direct capital investments. Additional compliance burden: since January 2026, the German Federal Ministry of Finance (BMF) has activated the mandatory reporting form. All affected individuals must declare their emigration and fund positions to the tax office.

According to a recent analysis by KPMG Germany on the exit tax from 2025, this rule potentially affects millions of German investors. The BMF exit-tax form (January 2026) has been mandatory since the start of 2026.

Why is the destination country so decisive for the exit tax?

The mechanism is owed to a CJEU principle: the freedom of capital movement in the EU single market prohibits Germany from disadvantaging emigrants moving within the EU compared with someone relocating inside Germany. Hence the rule: emigration to EU/EEA = automatic, unlimited deferral, no security required, no interest. The tax is only due when the units are actually sold, whether in 5, 15 or 30 years.

For emigration to third countries (UAE, Switzerland, Caribbean) the tax is in principle immediately due. A 7-year instalment deferral is only possible if a double taxation agreement exists, mutual administrative assistance is granted and security is lodged. For many investors this is operationally impractical.

This asymmetry makes the choice of destination country the most important strategic decision in emigration planning. As an EU/EEA citizen, you can relocate to any EU/EEA country under free movement rights and register tax residency there without an investment-based residence permit, Golden Visa programmes exist for non-EU nationals who need one to gain the right to live in the EU.

Portugal Golden Visa + NHR 2.0: is Portugal the best choice for German investors?

How EU citizens relocate: As a German national you do not need a Portugal Golden Visa, EU/EEA citizens have the right to live in Portugal under free movement and simply register tax residency to establish it. The Portugal Golden Visa itself (funds from €500,000, arts/cultural heritage from €250,000, research funding from €500,000; the residential property route effectively no longer exists) is a route for non-EU nationals who need an investment-based permit to gain residence rights.

Tax, NHR 2.0: The Non-Habitual Resident (NHR) regime was reformed in 2024. The new status applies to individuals who pursue certain qualifying activities (science, technology, senior management). The tax rate is 10 per cent on foreign-source income for 10 years. For ETF income that is not Portuguese-sourced, this offers a substantial advantage compared with Germany's top marginal rate of up to 47 per cent.

Citizenship pathway: Portugal's Lei Orgânica 1/2026 (in force 19 May 2026) now sets naturalisation at seven years of legal residence for EU and CPLP nationals, or ten years for other nationalities, an EU passport with visa-free access to 184+ countries. Applicants whose AIMA fee was paid, or whose citizenship application was already submitted to IRN, before 19 May 2026 are grandfathered under the previous timelines. Permanent residency remains independently available after 5 years.

Verdict for Germans: Portugal is ideal for German nationals who wish to live in Europe long-term, aspire to eventual Portuguese citizenship and can benefit from NHR 2.0, relocation itself is immediate and free under EU free movement, with no investment or minimum-spend requirement for you as an EU citizen.

Greece Golden Visa: faster and cheaper than Portugal?

For DACH clients who need a swift solution to the exit-tax issue, relocating to Greece offers several advantages:

• No investment required for you: as an EU/EEA citizen, you relocate to Greece under free movement rights, simply register your address and apply for tax residency. (The Greece Golden Visa, from €250,000 via the start-up or cultural-heritage routes, is the route for non-EU nationals.)
• No backlog issue: unlike Portugal, Greece has no comparable administrative backlog. Processing times are considerably shorter.
• No minimum stay: Greek tax residency itself imposes no minimum-stay requirement to maintain your registration, ideal for clients who remain internationally active.
• Tax attractiveness: Greece offers a flat-rate alternative tax regime: foreigners moving to Greece who have never previously been tax-resident there can opt for a flat tax of €100,000/year on all foreign income, regardless of the actual amount.
• Citizenship pathway: after 7 years of residency in Greece, Greek citizenship is possible.

Important note on holiday lets: Airbnb-style lettings on Golden Visa properties have been prohibited in Greece since 2024. Investors relying on rental yields should factor this into their calculations.

Verdict for Germans: Greece is the ideal choice for German nationals who want to establish EU residency (and thus exit-tax deferral) quickly and without any investment, minimum spend or long-term residency obligations. Particularly attractive for clients who primarily seek tax protection and want to use Greece as the first step in a broader strategy.

Malta MPRP: is non-dom status optimal for German ETF investors?

The Malta MPRP is, from a tax perspective, the strongest EU programme for large German ETF investors. Here is the mechanism:

Deferral protection: Malta is an EU member. Emigration to Malta = automatic, unlimited deferral of the German exit tax under §6 AStG. No immediate payment, no interest, no security.

Non-dom status in Malta: as a Maltese tax resident without domicile (non-dom), foreign income that is not remitted to Malta is not taxed at all. Specifically: an ETF portfolio held in Germany or Switzerland that continues to generate income (dividends, interest) is not taxed in Malta as long as those funds are not transferred to a Maltese account. Only income actually remitted to Malta is subject to Maltese income tax (top rate 35 per cent).

Minimum tax: €15,000/year as a flat tax on Maltese income and foreign income actually remitted. For an investor with a €2 million ETF portfolio and potential annual income of €80,000-€120,000, this is an exceptional offer.

MPRP costs: €99,000 in government fees, plus a qualifying property: purchase from €375,000 or rental from €14,000 a year. Significantly more cost-effective than Portugal or Greece.

Note: the Malta CBI programme (citizenship by investment) was closed in April 2025. The MPRP (permanent residence) remains open and active. This is a residency programme, not citizenship.

Verdict for Germans: Malta MPRP is the most cost-effective EU option with the maximum tax advantage for ETF investors. Ideal for clients who do not seek a physical relocation but require EU tax residency for exit-tax deferral.

Cyprus: what does the new 60-day rule from April 2026 deliver?

Cypriot tax residency has improved considerably for German investors thanks to the April 2026 reform. The key points:

• New 60-day rule (from 7 April 2026): anyone spending at least 60 days of the tax year in Cyprus, no more than 183 days in any other country, with a professional or business activity in Cyprus and a permanent home available there, qualifies as a Cypriot tax resident, without the previous requirement of not being tax-resident anywhere else.
• Zero CGT on securities: Cyprus levies no capital gains tax on profits from the sale of securities (shares, ETFs, bonds). 20 per cent CGT applies only to the sale of real estate. For an ETF investor emigrating to Cyprus, all future gains are tax-free.
• Non-dom status: as a Cypriot non-dom, foreign income (dividends, interest from non-Cypriot sources) is exempt for 17 years from the Cypriot special levy GESY (0.65 per cent) and partly from income tax. This is the most generous non-dom regime in any EU country in terms of duration.
• EU/EEA deferral protection: Cyprus is an EU member, emigration to Cyprus activates the automatic deferral of the German exit tax.
• No investment needed for EU citizens: as a German national you relocate to Cyprus under EU free movement and simply register tax residency, no Golden Visa is required. (The Cyprus Golden Visa, €300,000 in real estate, is the route for non-EU nationals.)

Verdict for Germans: Cyprus is particularly attractive in 2026 thanks to the April reform: zero CGT on ETF sales, 17 years of non-dom, EU deferral protection and a lower minimum investment than Portugal. Ideal for investors who actively wish to realise capital gains once the exit tax has been deferred.

UAE Golden Visa: the zero-tax option, and what about deferral?

The UAE Golden Visa is for many HNWIs the most attractive option in the world: zero tax, international hub, English as the business language, top-tier infrastructure. The property route via AED 2 million (~€500,000) is in strong demand in 2026, an increase of +34.7 per cent in the first quarter.

For exit taxation, however: because the UAE is not an EU/EEA country, the automatic deferral does not apply. The exit tax is assessed as immediately due upon emigration to the UAE. Technically, a 7-year instalment deferral can be applied for (since a double taxation agreement exists between Germany and the UAE), but only under very strict conditions: security, annual instalments, reporting obligations to the German tax office.

Strategic combination: several Mirabello clients pursue the following structure: first relocate to an EU/EEA country (Greece or Cyprus, using free-movement rights, no Golden Visa required) for the deferral, then a gradual relocation to the UAE over a few years, once the deferred gains have been wound down through realised sales in the EU residence. This two-track strategy enables a long-term tax shift to the UAE's zero-tax environment without immediate exit-tax payment.

Since 2026, the UAE has also officially permitted dual citizenship, an important step that is relevant for selected investors.

Comparison: which country fits which German investor profile?

Note: all tax regimes require individual legal and tax advice. This table is intended as initial orientation. Mirabello Consultancy coordinates the structuring with specialist tax advisers in the destination country.

What next steps does Mirabello Consultancy recommend for §6 AStG planning?

The exit tax is not a topic to be left on the back burner. The BMF reporting form has been mandatory since January 2026, compliance pressure is rising month by month. Anyone starting emigration planning needs at least 12-24 months of lead time to implement the optimal strategy.

Mirabello Consultancy recommends the following steps:

1. Stocktake: portfolio analysis, which ETF/fund positions exist, what are the accumulated unrealised gains, what is the potential §6 AStG tax amount?
2. Destination decision: based on your priorities (tax advantage, lifestyle, EU passport, speed) we jointly select the optimal destination, for EU/EEA citizens this is a free-movement relocation, or, for non-EU family members, the matching investment residence route.
3. Application preparation: we coordinate the residence registration or, where an investment route applies (e.g. for non-EU family members), the Golden Visa application, from document preparation through due-diligence support to submission.
4. Tax structuring: in coordination with tax advisers in Germany and the destination country, we ensure the emigration runs correctly from a tax perspective, including deregistration in Germany, BMF notification and initial tax assessment in the new residence country.
5. Long-term support: residency renewal, citizenship pathway after 5-7 years, passport planning, we accompany you on an ongoing basis.

With 350+ successfully completed residency cases, a 99 per cent approval rate and headquarters in Zurich, Mirabello Consultancy is the first port of call for DACH HNWIs who wish to plan their emigration professionally. IMC member and ACAMS-certified, for the highest standards in investment migration. Read more on our credentials at About Mirabello Consultancy and explore our Best Citizenship by Investment Programmes 2026 hub for further options.

What are the most frequent questions on the exit tax and Golden Visa 2026?

Can I avoid the exit tax entirely if I move to an EU country?
Not entirely, but defer it indefinitely. If you emigrate to an EU/EEA state, the exit tax is automatically and free-of-charge deferred until you actually sell the units. If you never sell the units and pass them on to your heirs, the tax may, in certain configurations, be eliminated altogether. Full avoidance is possible through targeted annual realisations within allowances before emigration, but only partially and with limited effect for large portfolios.

How long does it take to establish tax residency in Greece?
As an EU/EEA citizen, registering Greek tax residency typically takes only a few weeks once you have an address and the required registrations in place, there is no Golden Visa processing time to factor in, unlike Portugal's backlog for non-EU applicants. Mirabello Consultancy coordinates the registration process to minimise delays.

Which country offers the best EU passport after relocation?
Portugal (seven years of residency for EU nationals under Lei Orgânica 1/2026, minimal physical presence required) offers the fastest route to an EU passport for a German national who relocates under free movement. Greece requires 7 years of residency. Malta has a separate citizenship programme for exceptional investors (3-5 years). Cyprus closed the Cyprus Investment Programme, there is no direct CBI route to citizenship.

Does the exit tax also apply to fund units held in a Swiss custody account?
Yes. The question of whether fund units are held in a German or foreign custody account is irrelevant for §6 AStG. What matters is the individual's tax residence in Germany (at least 7 of 12 years) and the holding of fund units with unrealised gains at the time of emigration. Custody location has no bearing on the tax liability.

How do I begin emigration planning with Mirabello Consultancy regarding the exit tax?
The first step is a complimentary consultation with our experts in Zurich. We analyse your portfolio structure, your goals and your tax starting position, and recommend specifically the optimal destination country and, where an investment route is actually relevant to you, the Golden Visa programme for your situation. Mirabello Consultancy is an IMC member, ACAMS-certified, with 350+ residency cases and a 99 per cent approval rate. Book your complimentary consultation now →