Hello,
I am seeking clarification on the potential triggering of exit tax in the following scenario:
Scenario: Relocation from both Germany and Austria
Would the German exit tax rules exclusively apply, given the individual's unlimited tax liability in Germany in accordance with Article 4(2)(c) of the DTT between Germany and Austria (i.e., German citizenship)?
Alternatively, would both exit tax regimes be applicable to the corresponding portions of wealth originating from the respective countries? For example, the stock account originated in Austria—would it be subject to Austrian exit tax? Is wealth originating from Austria subject to Austrian exit tax, even if the individual's tax residency is in Germany?
I would greatly appreciate your assistance in comprehending this matter.
Best regards.
I am seeking clarification on the potential triggering of exit tax in the following scenario:
- A person holds unlimited tax liability in Germany and limited tax liability in Austria, as determined by the respective Double Taxation Treaty (DTT) between the two countries.
- The individual generated income from employment in Austria, leading to the accumulation of a stock account with unrealized capital gains.
Scenario: Relocation from both Germany and Austria
Would the German exit tax rules exclusively apply, given the individual's unlimited tax liability in Germany in accordance with Article 4(2)(c) of the DTT between Germany and Austria (i.e., German citizenship)?
Alternatively, would both exit tax regimes be applicable to the corresponding portions of wealth originating from the respective countries? For example, the stock account originated in Austria—would it be subject to Austrian exit tax? Is wealth originating from Austria subject to Austrian exit tax, even if the individual's tax residency is in Germany?
I would greatly appreciate your assistance in comprehending this matter.
Best regards.