Leaving Germany with crypto: checklists

12 to 6 Months Before Emigration

• Choose a destination country and use the relevant country profile as a starting point for an advisory conversation.
• Engage a tax advisor — ideally both for Germany and for the destination country, best coordinated with each other.
• Initiate the § 2 AStG check if substantial economic ties to Germany are meant to continue (see the § 2 AStG classification in the relevant country profile).
• Review the portfolio: which positions are old or new holdings, which are at a gain, which are at a loss, which have already reached the German one-year period?
• Check whether a country-specific practical tip (selling before emigration, bringing along loss positions) applies to your own situation.
• Clarify residence permit and visa questions for the destination country.

6 to 3 Months Before Emigration

• Schedule and carry out tax-sensible sales (and any repurchases) according to the country-specific practical tips, while German unlimited tax liability unquestionably still applies.
• Sort out housing in the destination country — a lease, intent to buy, or accommodation for the first few months.
• Check whether and how the German home will be given up (termination; rule out subletting, since that can extend unlimited tax liability).

3 to 1 Month Before Emigration

• Export and save the complete transaction history of all exchanges and wallets — including accounts that might be closed.
• Prepare a mail forwarding order and re-registration of ongoing contracts.
• Check bank accounts and brokerage accounts with regard to the future residency.

The Move Itself

• Actually give up the German home — not just deregister. Deregistering with the residents' registration office alone doesn't end unlimited tax liability.
• Document the date the home was actually given up and the date of the move (handover report, final bills, travel records).
• Formally establish residency in the destination country, if a registration or notification is required for that.

The First Twelve Months After

• Prepare the German tax return for the year of emigration — even with emigration partway through the year, a return generally still has to be filed (especially because of the progression clause).
• Fulfill tax obligations in the destination country for the first time, following the forms and deadlines described in the relevant country profile.
• Establish ongoing documentation: cleanly record the purchase date, purchase price, and wallet allocation of every new position from the start.
• For borderline countries, go over your own assessment with the tax advisor again after the first full year.

Emigrating changes nothing about the existing crypto assets themselves, but it can affect whether the accounts used so far can keep being used. Two points should be checked before emigrating:

• Change of address: regulated providers require a current residential address as part of customer identification (KYC). An address that hasn't been updated is a compliance problem in its own right, even if nothing else changes about the tax situation.
• Geographic availability: not every provider actively serves every country. Within the EU, the MiCA Regulation does provide for passporting: a single authorization granted in one member state generally entitles the provider to offer services EU-wide (Art. 65 MiCAR). But to do so, the provider must have actually notified its supervisory authority of which countries it intends to operate in — an authorization alone doesn't automatically mean usability in every other EU country.

For emigration to a country outside the EU or EEA, MiCA passporting doesn't apply in any case; there, it's solely the provider's own terms of use that determine whether and how an account may be continued from there.

The more countries, exchanges, and wallets are involved, the more important seamless documentation becomes — not only because of the automated reporting systems DAC8 and CARF, but simply because many of the favorable classifications described here (old or new holdings, an expired holding period, a sale before or after establishing residency) can only be proven with clean documentation.

• For every position: the original purchase date, the purchase price in euros at the time of purchase, and the exchange or wallet used.
• Keep FIFO allocation separately per wallet or exchange, as German administrative practice requires — even if the destination country has different rules, this makes the later German assessment easier if you return.
• Export complete transaction histories regularly, not just shortly before filing the tax return — exchanges sometimes delete or restrict access to old data after a certain time, or when an account is closed.
• Archive evidence of when the home in Germany was given up (termination confirmation, handover report, re-registration confirmation) and evidence of establishing the new residency (lease, registration confirmation, residence permit) separately.
• For countries with calendar-year retroactivity (Thailand, Indonesia): keep your own count of days spent there, rather than estimating only at year-end.
• For portfolios that have grown across several countries: keep a single, continuous overview, rather than relying on memory or scattered exports from individual exchanges.

Heightened cooperation and evidence-preservation obligations apply to matters involving a foreign element (§ 90(2) AO): anyone relying on residency abroad has to actively provide the necessary evidence. If cooperation remains insufficient, the tax administration may estimate the basis for taxation (§ 162 AO). Avoidable mistakes:

• Evidence is only obtained once the tax office is already asking, or a dispute has arisen — by that point, some documents (old bank statements, login details for closed accounts) may no longer be obtainable. Better: collect it continuously during the time abroad, not only after the fact.
• The chronological documentation of stays has gaps or is contradictory — for instance, if the employment contract suggests continuous work abroad, but actual travel movements show frequent, longer stays in Germany.
• Different bodies receive contradictory information about your own address — a foreign address given to the employer, say, but the German address still showing up in older contracts or forms.
• Foreign-language documents are submitted without translation, even though the tax office can require a German translation.
• Changes in the facts — the parents later actually moving away, or the room being repurposed, for example — aren't reported afterward, even though a duty to correct (§ 153 AO) arises as soon as it becomes apparent that an earlier declaration was, or has become, incorrect.
• Requests from the tax office are answered only selectively or late, instead of presenting the facts completely and consistently on your own initiative.

The following points in particular speak against a German family foundation as an arrangement for emigrating:

• The destination country exempts holdings brought with you anyway — as with Austria for acquisition before 1 March 2021, Czechia after three years, Portugal after 365 days, or Croatia after two years. Then there's nothing to preserve.
• The destination country doesn't tax crypto gains at all, or only symbolically, as with the United Arab Emirates, Georgia, or Singapore. The effort would come to nothing.
• The hidden reserves are below a mid six-figure amount. Formation and administration costs, the substitute inheritance tax, and advisory expenses are then out of proportion to the saving.
• The emigrant isn't “ready for a foundation” — they have to accept that a legal person independent of their own will comes into existence, that they can no longer freely dispose of the assets contributed, that the decision is final, and that they themselves are bound by the charter just like any other governing body.
• The emigrant wants to dispose of all the assets in the short term. The foundation is an irrevocable tying-up of assets; whatever was put in belongs to it. Access exists only via loan repayment and distributions under the charter — and the latter are taxable for the recipient.
• The structure is recognizably formed for tax reasons alone. A foundation needs a genuine purpose distinguishable from the founder and actual implementation; if both are missing, the charge of an abusive arrangement (§ 42 AO) is a real risk.