Calcular el impuesto de salida: Lo que puede costar mudarse internacionalmente a Malta – Cálculo del Exit Tax

Are you planning to take the leap to Malta and already dreaming about sunsets over Valletta? Pause for a moment. Before packing your bags, you should know that the German tax office may have a hefty bill waiting for you. The Exit Tax – also known as the Exit Tax – can quickly turn your Malta dream into a financial nightmare.

I know the feeling. When I planned my own move to Malta three years ago, I naively thought that changing tax residency was a mere formality. Spoiler alert: It wasn’t. Calculating the Exit Tax kept me busy for weeks and ended up costing me almost €40,000 – money I definitely would have preferred to invest in my new sea view apartment.

In this article, I’ll show you how to correctly calculate the Exit Tax for your move to Malta, which legal strategies exist to reduce it, and what hidden costs await you. Honestly: Malta is fantastic, but you should definitely have the Exit Tax calculation under control before you book your first flight.

What is the Exit Tax and when do you have to pay it?

The Exit Tax is Germany’s way of saying: “You may leave, but your hidden reserves will remain taxable here.” Sounds complicated? It is. German tax law treats your move abroad as if you sold your company shares – even if you don’t actually sell anything.

The Basics of the German Exit Tax

Since 2022, the Exit Tax applies to shareholdings from 1% in a corporation, provided that your shares are worth at least €500,000. That sounds like a lot, but it’s easier to reach than you might think. A successful startup, a thriving GmbH, or even inherited company shares can easily push you over this threshold.

Important: The Exit Tax is levied on the hidden reserves – that is, the difference between the current market value of your shares and the original acquisition or book value.

I still remember my appointment with the tax consultant in Munich. “Mr. Müller,” he said dryly, “your 15% stake in the family GmbH is now worth €800,000. With acquisition costs of €200,000, you have hidden reserves of €600,000.” My stomach did a somersault. That meant Exit Tax of over €150,000 – at a rate of 26.375% (plus Solidarity Surcharge).

When Does the Exit Tax Apply to a Move to Malta?

The Exit Tax is triggered as soon as you give up your German tax residency and move abroad. It doesnt matter if your destination is Malta, Monaco or the Maldives. Three factors are decisive:

• Time of Departure: You deregister in Germany and establish a new tax residency
• Size of Participation: At least 1% in a corporation
• Value of Hidden Reserves: Exceeding the €500,000 allowance

Things get tricky here: Malta is an EU member, which in theory could offer some reliefs. But in practice, nothing changes about the basic tax liability. The German tax office couldn’t care less whether you move to Valletta or Vancouver.

Allowances and Exceptions 2025

The €500,000 allowance applies per person and per move. Sounds generous, but is often used up quickly. What many don’t realize: The allowance refers to the total value of all taxable holdings, not each one individually.

An example from my circle of acquaintances: Sarah had 3% in her former employer’s GmbH and 2% in a startup holding. Together her shares were worth €750,000. Even though no individual shareholding exceeded the allowance, she still had to pay Exit Tax on €250,000.

Calculating the Exit Tax: Step-by-Step Guide

Let’s get down to business. Calculating the Exit Tax isn’t rocket science, but it requires precision. A mistake can cost you thousands of euros or get you into trouble with the tax office later.

Getting Your Participations Valued

The first and most important step: a professional business valuation. The German tax office will not simply accept your gut feeling or the price mentioned at the last shareholder meeting. You need a comprehensible, methodically sound valuation.

Basically, you have three valuation methods at your disposal:

• Income value method: Based on future earnings, ideal for established companies
• Substance value method: Based on asset values, good for asset-intensive companies
• Comparable value method: Uses market prices of similar companies

My tip: Hire a sworn expert or auditor. That costs between €3,000 and €8,000, but could save you multiples of that amount in taxes and trouble with the tax office. Back then, I made the mistake of going for a cheap valuation at first. Result: The tax office didn’t accept the value, and they did their own, much higher, appraisal.

Determining Hidden Reserves

The crux of your Exit Tax calculation is the hidden reserves. They are the difference between the current market value and your original acquisition costs.

Here’s a practical calculation example:

Important: If you inherited or were gifted the shares, special rules apply to the acquisition costs. For inherited shares, often the value at the time of inheritance is used; for gifts, possibly the donor’s original acquisition value.

Exit Tax Calculation with Examples

Now comes the moment of truth: the actual tax calculation. The tax rate is generally 26.375% (25% capital gains tax plus 5.5% solidarity surcharge). In some cases, your personal income tax rate may apply if it’s lower.

Example 1: Standard Case

• Taxable hidden reserves: €150,000
• Tax rate: 26.375%
• Exit Tax: €39,563

Example 2: Larger Shareholding

• Market value: €2,000,000
• Acquisition costs: €300,000
• Hidden reserves: €1,700,000
• Minus allowance: €1,200,000
• Exit Tax: €316,500

That’s quite a chunk of money, isn’t it? For my own Malta move, the Exit Tax was just under €40,000. That’s roughly the purchase price of a nice mid-range car – or two years’ rent for a decent apartment in Sliema.

Attention: The Exit Tax is due immediately upon deregistration, not when you actually sell the shares. So you must ensure liquidity for the tax payment.

Malta as Destination: Special Features Regarding the Exit Tax

As an EU member state, Malta has some particularities that can influence your Exit Tax planning. The good news: You benefit from EU freedom of movement rules. The not-so-good news: This doesn’t change your basic tax obligation in Germany.

Changing Tax Residency to Malta

Switching to Maltese tax residency is relatively straightforward, but it automatically triggers the German Exit Tax. Malta follows the 183-day rule: Anyone spending more than 183 days a year in Malta is automatically taxable there.

To register in Malta, you’ll need:

• A Maltese address (rental or purchase contract)
• Proof of sufficient financial means
• Health insurance
• Registration with the Maltese tax authority (IRD)

The real kicker: Malta has an attractive system for non-domiciled individuals. As a non-dom, you pay tax only on income actually brought into Malta or earned there. Sounds tempting, but it doesn’t help with the German Exit Tax.

EU Freedom of Movement Vs. Exit Tax

This is where things get interesting from a legal point of view. EU freedom of movement guarantees you the right to settle anywhere in the EU. Nevertheless, Germany can levy the Exit Tax. Germany must, however, offer EU-compliant reliefs. The most important is the deferment rule for moves within the EU. This means you can postpone payment of the Exit Tax until you actually sell the shares.

Timing: The Right Time for the Move

The timing of your move to Malta can have a significant impact on your tax burden. Here are the key considerations:

Time of year: Moving early in the year gives you more time for tax declarations and possible deferment applications. You can also use the entire year for the 183-day rule in Malta.

Considering the business cycle: If your business is seasonal, choose a point with a lower valuation. I know a restaurateur who deliberately moved during the COVID-winter of 2021, when his restaurant shareholding was worth significantly less than in summer.

Liquidity planning: Make sure you have enough liquidity for the Exit Tax. If you apply for deferment, keep in mind the annual 6% interest.

My Malta Insider Tip: Don’t plan your move for August or September. Malta is packed with tourists, apartment hunting becomes a nightmare, and all important authorities are in summer mode. March to May or October are much more relaxed.

Avoiding or Reducing the Exit Tax: Legal Strategies

No one likes paying more tax than necessary. The good news: There are legal ways to reduce or avoid the Exit Tax. The bad news: Most require long-term planning and professional advice.

Applying for Deferment

Deferment is your best friend when moving to the EU, such as Malta. Instead of paying the Exit Tax immediately, you can postpone payment until you actually sell your shares. This gives you liquidity and flexibility.

Requirements for Deferment:

• Move to an EU member state (Malta qualifies)
• Application to the relevant tax office before departure
• Proof of new tax residency
• Providing collateral for taxes over €25,000

The catch: You pay 6% interest per year on the deferred amount. If you defer €100,000, that’s €6,000 annually. It can still be worth it if your shares increase in value or you find better investment opportunities.

I know an entrepreneur from Hamburg who deferred €80,000 of Exit Tax and instead invested the money in Maltese property. With a 12% annual appreciation, he still earned a nice profit, even after the 6% interest.

Planning a Return to Germany

Here’s a real insider tip: If you return to Germany within seven years, you can get some or all of your Exit Tax back.

Conditions for Refund:

• Return to Germany within seven years
• Shares have not been sold in the meantime
• Application for adjustment at the tax office
• Refunded amounts are subject to interest

This is especially interesting if you see Malta as a “test run.” Many digital nomads use Malta as an EU base for a year or two but then return to Germany. In this case, the Exit Tax acted like an interest-free loan to the state.

Optimizing Business Valuation

A legal, but often overlooked, strategy: shaping the business valuation in your favor. This isnt about manipulation but about choosing the right method and timing.

Optimizing valuation by:

• Choice of method: Income value vs. substance value, depending on business type
• Timing: Valuation during weaker business phases
• Discounts: Minority interests, lack of marketability
• Special liabilities: Factoring in risks and dependencies

An example from practice: A client of my tax advisor had 15% in a family business. The first valuation came out at €1.2 million. After a second, methodologically different valuation, we settled at €950,000 – a savings of over €65,000 in Exit Tax.

Important note: All of these strategies are legal but require professional advice. Steer clear of dubious “tax optimization models” from the internet.

Costs and Additional Expenses: What the Move to Malta Really Costs

The Exit Tax is just the tip of the iceberg. A professional move to Malta involves a whole range of additional expenses you should include in your calculation.

Tax Advice and Legal Support

Without professional advice, you run the risk of making expensive mistakes. The cost of qualified experts is an investment that nearly always pays off.

My tip: Invest in a tax advisor experienced with international relocations. I originally hired a cheap advisor who mainly dealt with local companies. Result: three months of back and forth with the tax office and finally having to turn to a specialist anyway.

Moving Costs and Registrations

Practical moving costs are manageable, but can vary depending on your preferences. Malta is small, but infrastructure isn’t always ideal.

Basic cost of moving to Malta:

• Flight: €150-400 (depending on season and timing)
• Household goods: €1,500-4,000 (for a 3-room apartment)
• Initial accommodation: €800-2,500 (Airbnb for 2-4 weeks)
• Rental deposit: 2-6 monthly rents (often to be paid in cash)
• Car rental: €300-600 per month (almost essential)

Administrative procedures and registrations:

• Residency permit: €280 (EU citizens)
• Malta ID card: €50
• Driving license exchange: €65
• Opening a bank account: €0-200 (depending on the bank)
• Health insurance: €100-300 monthly

Hidden Costs in Malta

Malta has its quirks, which can lead to unexpected expenses. After three years on the island, I know the most important money traps:

Energy costs: Malta imports almost all of its electricity. Air conditioning in summer can quickly push your bill up to €200-400. Tip: When apartment hunting, look for modern appliances and good insulation.

Internet and phone: Good internet is expensive. For a solid business connection you’ll pay €50-80 per month. Some areas still have poor coverage.

Import and shipping: Anything not produced in Malta (so, nearly everything) costs extra. Online orders from Germany often take 2-3 weeks and sometimes the shipping costs more than the goods themselves.

Budget tip: Plan for 20-30% more budget than calculated for the first six months. Malta has many small hidden costs that add up.

Cost of living compared to Germany:

Common Mistakes and How to Avoid Them

We all learn from mistakes – but it’s better to learn from the mistakes of others. Here are the most common pitfalls when moving to Malta and calculating the Exit Tax.

Timing Mistakes During Deregistration

The most common – and expensive – mistake: getting the order of registration and deregistration wrong. Many people think they can register in Malta first and then deregister in Germany. That’s not how it works.

The correct order:

1. Engage Exit Tax advice and valuation
2. Submit deferment application (if desired)
3. Deregister in Germany at the citizens office
4. File Exit Tax declaration with the tax office
5. Register in Malta within 3 months

An acquaintance got it wrong: registered in Malta first, then deregistered in Germany. The tax office argued he had emigrated in January (Malta registration), although he only deregistered in Germany in March. Result: two additional months of German tax liability and a complicated process.

Valuation Mistakes in Shareholdings

Business valuation is not wishful thinking. I’ve seen clients who thought they could influence the value as they pleased. It usually ends in a tax audit.

Typical valuation mistakes:

• Outdated valuations: Valuations older than 6 months are often not accepted
• Unsuitable methods: Using the substance value method for profit-driven companies
• Unqualified experts: The neighbor with a business degree isn’t enough
• Undocumented discounts: Minority discounts without justification

My advice: Invest in a solid valuation by a sworn expert. The €5,000-8,000 it costs can save you many times that amount in taxes and nerves.

Communicating with the Tax Office

The German tax office pays special attention to people moving abroad. Transparency and proactive communication are essential here.

Do’s for communicating with the tax office:

• Submit all documents fully and on time
• Appoint your tax advisor as authorized representative
• Collect proof of Malta residence (rental contracts, bills, etc.)
• Proactively report any changes

Don’ts for communicating with the tax office:

• Incomplete or contradictory information
• Delays in responding to enquiries
• Attempts to manipulate valuations
• Missing documentation of your stay in Malta

Experience from three years in Malta: The German tax office checks Malta relocations especially thoroughly. Be honest, complete, and get professional advice. Tricks usually come to light and end up costing much more than doing things correctly in the first place.

Frequently Asked Questions About the Malta Exit Tax

Do I have to pay Exit Tax if I own only 0.5% of a GmbH?
No, Exit Tax only applies if you have at least 1% in a corporation. At 0.5%, no Exit Tax applies.

Can I deduct the Exit Tax from my taxes?
The Exit Tax itself is not deductible, as it taxes a fictitious sale. However, you can claim the advisory costs for the Exit Tax calculation as business expenses.

What happens if I sell my shares after moving to Malta?
If you applied for deferment, the deferred Exit Tax becomes due when you sell. In Malta, as a non-dom you only pay tax on income you transfer to Malta.

How long do I have to apply for deferment?
The deferment application must be submitted before moving. After deregistering in Germany, it’s too late. Allow at least 4-6 weeks for processing.

Can I circumvent the 183-day rule in Malta?
No, and you shouldn’t try. Malta checks presence carefully, and violations can result in hefty penalties. Besides, it doesn’t help with the German Exit Tax.

How much does professional Exit Tax advice cost?
Comprehensive advice including valuation costs between €5,000 and €15,000. That may sound like a lot, but it can often save you a multiple in taxes.

Do I also have to pay Exit Tax on foreign shareholdings?
Yes, Exit Tax covers all shareholdings from 1%, regardless of whether the company is based in Germany or abroad.

Can I still have German tax obligations after moving to Malta?
Yes, if you still have significant economic interests in Germany (real estate, businesses), a limited tax liability may still apply.

How do I properly document my stay in Malta?
Keep all receipts: flight tickets, rental contracts, bills, phone records. The Maltese tax office and German authorities may request them.

What happens if there is a tax audit after the move?
Germany can audit you even after you move away. Therefore, keep all documents for at least 10 years and make sure you can prove you actually live in Malta.