Vietnam: crypto taxes when leaving Germany
Destination Vietnam: holding period, tax rate, classification under section 2 AStG, exit taxation and the five scenarios from the year of departure to a return to Germany.
- Leaving Germany does not by itself trigger German tax on crypto held as private assets. It is different for business assets (section 16(3a) EStG) and shares in a company (section 6 AStG). Whether section 2 AStG or the destination country's law then applies depends on the individual case.
- Holding period: none
- Standard rate on crypto gains: 0.1% on the gross value of each transaction, not on the net gain; current income (for residents): progressive schedule from 5% to 35%
- Classification under § 2 AStG: No
- Crypto exit tax: Not known
At a glance
| Holding period | none |
|---|---|
| Standard rate on crypto gains | 0.1% on the gross value of each transaction, not on the net gain; current income (for residents): progressive schedule from 5% to 35% |
| Classification under § 2 AStG | No |
| Crypto exit tax | Not known |
| Inheritance tax treaty with Germany | No |
| Registration after the move | No tax registration obligation with a deadline known; immigration-law (not tax) registration obligation with the police, penalty of around €110–190 for missing the deadline |
| Tax residency certificate | Likely strictly tied to 183 days; even the lease alternative requires a term of 183 days |
| DAC8/CARF | CARF: no commitment so far (as of late 2025/early 2026); DAC8: No information |
Crypto taxation in Vietnam
- Legal framework: Since 1 January 2026, crypto assets are civil-law-protected property; use as a means of payment remains banned. The central tax rules only took effect between March and July 2026.
- Transfers (sales): From 1 July 2026, income tax of 0.1% on the gross value of each transaction, regardless of gain or loss (Circular 32/2026/TT-BTC, which provisionally treats crypto assets like securities). Individuals are captured regardless of residency once they transfer through a Vietnamese crypto service provider. No FIFO, LIFO, or average price; acquisition cost plays no role, and the tax applies even when selling at a loss.
- Mining, staking, liquidity mining, airdrops, hard-fork tokens: receipts with no counter-transaction don't trigger the 0.1%. Circular 32/2026/TT-BTC contains no crypto-specific special rule for current income from mining, staking, or airdrops; their classification therefore follows the general rules of Vietnamese income tax law. They count as other personal income under the general progressive schedule for resident individuals (five tiers since tax year 2026: 5%, 10%, 20%, 30%, and 35%). If the tokens are sold later, 0.1% additionally applies.
- Collection, filing: licensed crypto service providers (VASPs) withhold the tax on every confirmed transaction; Circular 41/2026/TT-BTC of 6 April 2026 regulates declaration, withholding, payment, and annual settlement; requirements need to be checked in the individual case. As things currently stand, a separate declaration obligation mainly applies to people already required to file their own tax return, for instance when trading through unlicensed or foreign platforms, whose use remains regulatorily uncertain (a dedicated decree on administrative penalties since 2026).
- VAT, wealth, inheritance: transferring and trading are exempt from VAT; organizations established in Vietnam pay 20% corporate tax on income from crypto transfers. No general wealth tax. Inheritances and gifts: 10% income tax on the value above VND 20 million (from 1 July 2026); transfers between spouses, parents and children, grandparents and grandchildren, and biological siblings are exempt.
Classification under § 2 AStG
Vietnam clearly passes the burden comparison: at €77,000, the five-tier schedule applicable from 2026 produces, by our own calculation, around €19,100 against about €21,200 in Germany — around 90%, and thus well above the two-thirds threshold of €14,100. The 0.1% transaction tax isn't preferential taxation under § 2(2) no. 2 AStG: it attaches to the type of transaction and applies to all private investors, nationals or newcomers, residents or non-residents alike. The personal privilege the Federal Fiscal Court requires is missing; Vietnam has no non-dom system.
The five scenarios
Year of departure
- German unlimited tax liability only ends once residence and habitual abode are actually given up. In Vietnam, tax residency arises for anyone staying at least 183 days in a calendar year or a continuous twelve-month period from arrival, who has registered a permanent residence, or who rents accommodation for at least 90 days within the tax year.
- If the German home is already given up at the time of a crypto sale, the gain isn't domestic income under § 49 EStG; if both homes still exist in parallel, the tie-breaker decides.
- Since 17 February 2026, Vietnam has been on the EU list of non-cooperative jurisdictions for tax purposes, because it doesn't meet OECD standards on exchange of information on request. Nothing applies automatically; Germany first has to adopt the list into the Tax Haven Defense Ordinance. If Vietnam remains listed at the review in October 2026, tightened controlled-foreign-company taxation, withholding-tax measures, increased cooperation obligations, and, in extreme cases, denial of benefits under the double tax treaty threaten from 1 January 2027. Anyone planning to emigrate to Vietnam, or already resident there, should keep an eye on how the list develops at least until the end of October 2026.
First year after leaving
- Licensed exchanges withhold the 0.1% automatically: on a sale worth €50,000, that's €50, regardless of gain or loss. For frequent traders, this can add up more than a gain-based tax.
- With an exchange not licensed in Vietnam, nobody automatically handles the withholding; administrative practice for this case isn't yet settled.
More than ten years
- Nothing changes for income tax purposes (current position).
- No separate German-Vietnamese inheritance tax treaty: for German nationals, extended unlimited inheritance tax liability applies if the deceased or donor was fully taxable in Germany within the last five years before the inheritance; after more than ten years, this window is closed.
Moving on to a third country
- No exit taxation of its own for privately held crypto assets. Before a larger onward move, confirmation by a Vietnamese tax advisor is advisable; administrative practice on a possible exit-taxation provision is likely still developing.
Returning to Germany
- No special tax on the Vietnamese side. Re-establishing a residence or habitual abode in Germany brings unlimited tax liability back into effect. The original acquisition date still counts: if a position has been held for longer than a year in total, a later sale is tax-free under § 23 EStG.
The otherwise common advice to realize gains tax-free in Germany before emigrating only applies here to a limited extent: at 0.1% of the gross transaction value, the difference between a sale before and after emigrating is generally small. More important is whether a licensed Vietnamese exchange or a foreign platform is used.
Show sources
- Convention between the Federal Republic of Germany and the Socialist Republic of Vietnam for the Avoidance of Double Taxation of 16 November 1995, BGBl. 1996 II p. 2623, in force since 27 December 1996 – double tax treaty
- § 32a EStG – German income tax in the burden comparison
- Personal Income Tax Law No. 109/2025/QH15 of 10 December 2025 – five-tier schedule, personal deduction, 0.1% on the transfer price of digital assets (fns. 336, 337, 340, 345); Art. 26 – tax on inheritances and gifts
- Decree 253/2026/NĐ-CP – implementation of the Personal Income Tax Law
- BFH, judgment of 14 January 2025 – IX R 37/21 – preferential taxation, personal privilege
- Circular 32/2026/TT-BTC of the Ministry of Finance – VAT, corporate tax, and income tax for transactions with crypto assets, 0.1% regardless of residency, VAT exemption (fns. 337, 340, 341, 342, 345)
- Circular 41/2026/TT-BTC of 6 April 2026 – declaring, withholding, paying, and annually settling taxes in the crypto-asset market
- Decree 284/2026/NĐ-CP – administrative violations in the area of crypto assets
- Value-Added Tax Law No. 48/2024/QH15, amended by Law 90/2025 and Law 149/2025, implemented by Decree 181/2025/NĐ-CP, supplemented by Decree 359/2025 – VAT
- Corporate Income Tax Law No. 67/2025/QH15, implemented by Decree 320/2025/NĐ-CP – corporate tax of 20%
- Personal Income Tax Law No. 04/2007/QH12, as amended, implemented by Decree 65/2013/NĐ-CP, supplemented by Decree 12/2015 – income tax for earlier periods
Questions about Vietnam
Is there a holding period for crypto in Vietnam?
How high is the tax on crypto gains in Vietnam?
Is Vietnam a low-tax country under section 2 AStG?
Does Vietnam have an exit tax on crypto?
Legal position: country data 08/2026 (status of the book). Sources are listed in the "Sources" section. 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; we coordinate with local advisers. The § 2 AStG classification is our own calculation based on the 2026 tariff and is not an official ruling. Where this English text and the German text differ, the German text prevails.