What should a good tax adviser point out when I leave Germany to Malta?
What a good adviser should raise on their own when you leave Germany with bitcoin to Malta, with a checklist for the advisory meeting and a list of questions. The points rely on the country profile for Malta.
- A good adviser first asks about your situation: nationality, earlier tax liability, interests in Germany, holdings.
- Holding period: none
- Section 2 AStG classification: Individual: generally not a low-tax country, but the non-dom regime can count as personal preferential taxation
- The law of Malta is for an adviser on the ground to assess; a German adviser assesses the German side and coordinates.
What your adviser should raise on their own
Eight points from the country profile for Malta. Each says why it matters for your meeting.
Holding period
none It helps decide whether a sale before or after the move makes sense for tax purposes. That should be worked out with your numbers, not answered in general terms.
Standard rate on crypto gains
0% (coins, private); up to 35% for commercial activity Which type of income applies to your transactions determines the actual rate. The standard rate alone says little.
Classification under § 2 AStG
Individual: generally not a low-tax country, but the non-dom regime can count as personal preferential taxation Whether section 2 AStG applies depends not only on the country but also on nationality, earlier tax liability and substantial economic interests in Germany.
Crypto exit tax
Not known A country may tax itself when you move on or change status. That belongs in the planning before you move.
Inheritance tax treaty with Germany
No Without a treaty, German extended unlimited inheritance tax liability for German nationals can still matter for years after leaving.
Registration after the move
No reliable finding Deadlines and penalties for registration affect you from the first day in the destination country.
Tax residency certificate
According to available sources, possible from actual, permanent relocation (regardless of the 183 days); processing takes 4–6 weeks according to these sources You need proof of residency to support your position towards the German tax office and the destination country.
DAC8/CARF
DAC8 transposed into Maltese law since 1 January 2026; crypto service providers' first report due by 30 September 2027 for the year 2026 Reports from platforms can make your declarations verifiable later. Find out who reports what.
Checklist for the advisory meeting
List of questions
Questions you can ask. Good answers are specific and name their basis.
- In your assessment, does Malta count as a low-tax country under section 2 AStG, and what calculation is that based on?
- Which of the conditions of section 2 AStG apply to me and which do not?
- How will my existing holding period be counted in Malta, and what happens to positions I sell or buy back before the move?
- Which type of income does Malta apply to my transactions (sale, swap, staking, lending), and at what rate?
- Does Malta have an exit tax if I move on later, and how would it apply to my holdings?
- What happens if I return to Germany, and can the same gain be taxed twice?
- Which registration duties and deadlines apply in Malta, and what happens if I am late?
- When and how do I get a tax residency certificate for Malta?
- How do I prove residency abroad to the German tax office, and which documents do I collect from today?
- Who advises me on the law of the destination country, and how do you coordinate with that adviser?
- Which reports (DAC8, CARF) concern my platforms, and what follows for my declarations?
- What should I definitely not do before the move?
Warning signs
- The adviser says in general that a country is "tax-free" or "risk-free" without asking about your personal situation.
- Nothing is said about section 2 AStG or exit taxation.
- There is no list of evidence and no statement on how giving up the home is proved.
- The law of the destination country is assessed without pointing out the limits of the adviser's own scope.
- Results are promised without having seen your numbers.
Questions about the advisory meeting (Malta)
What should my tax adviser tell me when I leave Germany to Malta?
Can my German tax adviser assess the law of the destination country?
How do I prepare for the advisory meeting?
Legal position: country data 08/2026 (status of the book). The figures are abridged and are not advice on an individual case. The tax law of the destination countries and immigration law are outside our German advisory scope. Where this English text and the German text differ, the German text prevails.