Austria’s exit tax (Wegzugssteuer), also known as Exit Tax, under § 27(6) EStG taxes deemed capital gains on investment assets as soon as individuals permanently move their residence abroad. It is particularly relevant for entrepreneurs with GmbH shareholdings, investors and digital nomads.
Austria’s exit tax applies automatically if you, as a tax-resident individual, permanently relocate your residence or habitual abode (more than 183 days per year) abroad. It triggers a deemed disposal of your investments: all hidden reserves, i.e. the increase in value between acquisition costs and current market value, are immediately subject to 27.5% capital gains tax (KESt), even though no actual sale takes place.
Unlike Germany, Austria has no 1% participation threshold, meaning even small portfolio gains or minority GmbH stakes are covered. Those most affected include GmbH shareholders, angel investors with start-up portfolios and online entrepreneurs moving to Dubai, Portugal or Cyprus.
Only individuals with investment assets held as private wealth are affected. Legal entities can avoid the rule. The key conditions are as follows:
Permanent departure: giving up your Austrian residence (handing in the Meldezettel)
Investments with hidden reserves that arose during Austrian tax residency
No minimum participation required (even a 0.1% GmbH share counts)
Important exceptions:
Temporary stays abroad under 183 days (business secondment)
Assets with no increase in value (acquisition cost = market value)
Note the reporting obligation: the move must be informally reported to the tax office within one month. Failure to report can lead to late-payment interest of 2% per month.
Practical tip: when moving to Switzerland or the UAE (third countries), the tax is due immediately—so ensure you plan sufficient liquidity!
§ 27(6) EStG covers only investments with positive hidden reserves. Overview:
Asset type | Examples | Tax treatment |
Shareholdings | GmbH shares, AG shares, share capital | 27.5% KESt on the increase in value |
Securities | Shares, bonds, options, crypto | 27.5% on price gains |
Investment funds | ETFs, property funds, mixed funds | Deemed gain taxed in full |
Other | Receivables with interest income | Only the investment-income components |
Excluded are: real estate, bank balances without interest, business assets, art/tangible assets and pension entitlements.
For GmbH shareholders: the full business value minus paid-in capital is taxed. With a €1m market value and €100,000 paid in, that is a €247,500 tax burden.
The calculation is straightforward and transparent. Just follow these three steps:
Determine market value: valuation as at the departure date (book value, expert report, stock market price)
Calculate hidden reserves: market value minus acquisition costs (including broker/notary fees)
Apply KESt: 27.5% to the entire hidden reserve (no partial-income method!)
Item | Amount |
Capital contribution (2015) | €200,000 |
Company value on departure in 2026 | €2,000,000 |
Value of the stake (50%) | €1,000,000 |
Hidden reserve | €800,000 |
Exit tax | €220,000 |
Liquidity trap: there is no actual sale of the shares, yet you still bear the full tax charge immediately. For moves to third countries without the option of deferral, this is a significant burden—especially for entrepreneurs planning an exit.
Austria differentiates strictly by destination country. You should therefore align your planning with the rules that apply to your target jurisdiction:
EU/EEA countries (Portugal NHR, Cyprus, Malta):
Interest-free deferral possible for an indefinite period
Due only upon actual sale or a further move
Security required (e.g. guarantee)
Third countries (Dubai, Switzerland, USA):
No deferral; tax must be paid in full within 1 month
Triggers the reporting obligation to the tax office
Case-law similar to BFH: in 2024 the OGH confirmed that EU deferrals are compatible with EU law. So consider EU destinations for maximum flexibility.
Since the 2024 AT-DE treaty reform (Art. 13 repealed), there is a risk of genuine partial double taxation:
Austria taxes the hidden reserve on departure (27.5%)
Germany taxes again upon a later sale (up to 30% income tax + trade tax)
Solutions:
Credit the Austrian KESt in the destination country (check the treaty clause)
Sell in Austria before leaving
Use an EU holding company as an intermediate step
For those moving to Switzerland, the AT-CH treaty applies and full credit relief is possible.
Disclaimer: this article provides general information and does not constitute individual tax or legal advice. Specific structures should always be coordinated with a tax adviser or a specialist lawyer for international tax law.
Possible strategies:
Choose an EU/EEA destination: you deliberately opt for an EU or EEA country such as Portugal, Cyprus or Malta as your new place of residence. This allows you to benefit from the interest-free deferral of the exit tax, which becomes due only upon an actual sale or a later move to a third country. This strategy postpones the liquidity burden indefinitely and increases planning certainty.
Set up a holding company: before leaving, you establish a holding company (e.g. an Austrian GmbH or a Cypriot Ltd.) to which you transfer the operating GmbH shares. The individual then holds only shares in the holding, while the value-driving operating company sits below. The exit tax then applies only to the holding stake—often with lower hidden reserves.
Staggered sales: you realise the hidden reserves in smaller tranches over 2–3 years before the planned move, e.g. through partial share sales or distributions from the GmbH. Each step does trigger KESt, but it avoids a large one-off payment on departure. The remaining reserves are then largely “unloaded” when § 27(6) EStG applies.
Family foundation: you contribute your investment assets (shares, GmbH interests, portfolio) tax-free into a private Austrian family foundation. The foundation becomes the sole owner, while you act as founder or beneficiary. Upon leaving, the individual no longer directly holds taxable investment assets and the exit tax falls away entirely.
Asset protection: before leaving, you arrange targeted distributions, shareholder loans or bonus payments from the GmbH to yourself. These funds reduce hidden reserves in the company because book gains have already been realised and taxed. On a later departure, only a fraction of the original value increase remains taxable.
Timing rule: allow at least 12–18 months’ lead time for valuations, approvals and coordination with the tax office.
GmbH shareholders (100% ownership): the full company value is taxed—at a €5m valuation, up to €1.375m of tax.
Angel investors: aggregated valuation of all start-ups (goodwill counts!)
Digital nomads: portfolio gains over 10 years (e.g. Bitcoin +1,000%)
Property investors: lucky—only the operating company shares are relevant.
10-point plan for a stress-free move:
List all investment assets (portfolio, shareholdings)
Have the market value assessed by an expert
Calculate hidden reserves (create an Excel spreadsheet)
Choose an EU/EEA destination for deferral or plan liquidity
Report the departure to the tax office within 1 month
Review the destination country’s tax treaty (double taxation)
Contact a tax adviser (valuation + structuring)
Document acquisition costs (contracts, invoices)
Plan succession/continuity for the operating GmbH
Test a 3-month “trial move” (183-day rule)
Austria’s exit tax in 2026 hits entrepreneurs with GmbH stakes and investors with securities particularly hard: 27.5% capital gains tax on all hidden reserves, with no participation threshold and no actual sale—yet with an immediate liquidity impact. While EU/EEA destinations such as Portugal or Cyprus allow interest-free deferral, third countries like Dubai or Switzerland require the full tax amount within one month. With targeted planning (holding structures, timing, pre-realisation), up to 80% of the burden can nonetheless be legally reduced or deferred.
Reducing exit tax requires early, strategic planning, often with a 12–18 month lead time. Our international tax specialists analyse your individual structure, develop a legally robust exit strategy and support the coordination with the tax office.
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No. As soon as you permanently move your residence or habitual abode abroad, unlimited tax liability in Austria ends. You are then only subject to limited tax liability on Austrian-source income (e.g. rented property). The exit tax under § 27(6) EStG applies once upon departure and captures the hidden reserves at that time. After that, there is no ongoing obligation.
Yes. The exit tax is a one-off charge as at the departure date. It taxes the hidden reserves at that point on a deemed basis. If you move to the EU/EEA it is deferred interest-free (due only on sale); for third countries it must be paid immediately. After that it no longer applies, and subsequent increases in value abroad remain tax-free.
Yes. All individuals with investment assets (GmbH shares, shares, funds) are affected. No minimum participation is required, unlike in Germany. Even private individuals with small securities portfolios or 1% start-up stakes pay 27.5% KESt on hidden reserves. Pure employees without investment assets are excluded.
