Country corridor briefGermany → United Arab Emirates

Moving from Germany to the UAE: §6 AStG first

For a German founder or substantial shareholder, the UAE's 0% personal income tax is not the first question. The first question is whether German §6 AStG exit tax applies to a 1% or larger company stake after seven of the last twelve years.

The German exit-tax gate

Germany's §6 AStG exit tax applies where a person had unlimited tax liability for seven of the last twelve years and holds at least 1% of a company. The shareholding test, holding period and departure date need to be mapped before the UAE move.

Germany has no preferential HNW or expat regime, no investment-residency route and no statutory day-count safe harbour. A home available for use can establish residence; habitual abode is about 183 days in practice.

The UAE result after a real exit

The UAE has no personal income tax on wages, investment or real estate income, no capital-gains, dividend, wealth or inheritance tax, and no social security for non-GCC nationals. Business turnover exceeding AED 1,000,000 in a calendar year can bring a natural person into corporate tax. The standard 9% rate applies to taxable income above AED 375,000, not turnover.

That local result is attractive only once German residence has actually ended and the exit-tax cost has been priced.

Shareholder planning is not visa planning

The UAE Golden Visa property route is AED 2,000,000 subject to the applicable ownership and application conditions. It establishes an immigration path, not a German tax exit. The business, home and family facts must move with the person.

Before you move

  • A 1% company stake can bring §6 AStG into scope after seven of twelve years.
  • Germany has no statutory day-count safe harbour; a home available for use can matter.
  • The AED 1,000,000 business-turnover threshold determines natural-person corporate-tax scope; 9% applies to taxable income above AED 375,000, subject to applicable rules and reliefs.

Continue your research

Request a private assessment

Tax rates are only the first screen. Residency, ownership, treaty position and succession can change the outcome.

Request a private assessment