Moving from Germany to Bulgaria: The Wegzugsteuer Guide (2026)

Germany's exit tax, Wegzugsteuer under §6 of the Außensteuergesetz (AStG), is the single biggest reason a German founder cannot just pack up their GmbH and move to Bulgaria. Since the 2022 reform, the rules are stricter, the interest-free EU deferral is gone, and the tax office has more visibility on your move than ever.

This is not a legal opinion. It is a practical map of how founders actually structure moves from Germany to Bulgaria without triggering an exit-tax bill they cannot pay.

What Wegzugsteuer actually taxes

§6 AStG taxes the unrealised capital gains on your shares in a corporation when you cease to be an unlimited-tax-resident of Germany, provided:

• You have been resident in Germany for at least seven of the last twelve years, AND
• You own at least 1% of the corporation (any corporation, German or foreign) at any point in the five years before the move.

The taxable amount is the fair market value of your shares on the day residency ends, minus your acquisition cost. That gain is taxed at your personal income tax rate under the Teileinkünfteverfahren (60% of the gain is included), plus solidarity surcharge and church tax where applicable. Effective rate usually falls in the 27% to 30% range.

On a GmbH you built up to €1,000,000 in value with €25,000 of acquisition cost, that is roughly €292,500 of exit tax the day you move.

What changed in 2022

Before 2022, moving inside the EU/EEA meant an automatic, interest-free, indefinite deferral of the tax. That is gone.

The current rules:

• Tax is due immediately on the day residency ends.
• You can apply for payment in seven equal annual instalments (§6 Abs. 4 AStG).
• Security (a bank guarantee, usually) is required for the instalment plan.
• If you sell the shares, take a hidden distribution, or die during the seven-year window, the remaining tax accelerates.
• Interest may be charged on late instalments.

The seven-year instalment plan is the closest thing to relief that still exists, and it costs real money to arrange.

The three structures that actually work

1. Start fresh in Bulgaria, wind down the GmbH

If your GmbH is under a few hundred thousand in value and most of it is retained cash rather than goodwill, the cleanest path is often:

1. Distribute all retained earnings as a final dividend (pay the Kapitalertragsteuer).
2. Set up a Bulgarian EOOD.
3. Move new business to the EOOD.
4. Liquidate the GmbH (Liquidationsbesteuerung applies, but on a much smaller residual value).
5. Move personal tax residency after the GmbH is dissolved, so there are no shares to trigger §6.

This works because there is nothing left to exit-tax. It only works if you can time it and if your GmbH's ongoing value is not tied to non-transferable customer relationships.

2. Keep the GmbH as a legacy entity

For founders whose GmbH holds meaningful goodwill or long-term contracts:

1. Set up the Bulgarian EOOD for all new business.
2. Freeze new contracts in the GmbH; let existing ones run down.
3. The GmbH's fair market value drops over time as recurring revenue moves.
4. Move personal residency once the FMV is low enough that Wegzugsteuer is manageable, or after distributions have depleted the reserves.

The GmbH itself can continue to exist. Owning shares in it as a Bulgarian resident is fine; you just triggered exit tax once at the move.

3. Use the seven-year instalment plan

If neither of the above works, apply for §6 Abs. 4 instalments before you deregister. Requirements:

• File the application with your Finanzamt in advance.
• Provide security (usually a bank guarantee for the full amount, sometimes reduced).
• Report annually while instalments are running.

This is what your Steuerberater will arrange. Budget it into the move.

What triggers §6 that founders miss

The tax office reads the statute broadly. These also trigger it:

• Transferring shares to a non-resident spouse or trust. The "Ersatztatbestand" catches gifts and transfers that reduce Germany's future tax claim.
• Giving up German residency mid-year while still holding shares. The trigger date is the day you deregister, not the calendar year end.
• Moving to a country without a data exchange treaty. Bulgaria is fine (EU + CRS), but the instalment plan may be denied for non-cooperative jurisdictions.
• Changing your center of vital interests without formally deregistering. German courts can find you were no longer resident even if you kept the Anmeldung.

Bulgarian tax residency: the other side of the move

Triggering the exit means nothing if Bulgarian tax residency is not properly established. Bulgaria uses the 183-day rule plus center of vital interests. You need:

• More than 183 days per calendar year in Bulgaria, OR
• A Bulgarian home that is available to you year-round AND a demonstrable centre of vital interests (family, primary bank accounts, healthcare, social ties) in Bulgaria.

If you keep a house in Germany, keep German health insurance, and fly back every weekend, the German tax office will argue you never actually left. That is a separate fight from §6 and it can undo the whole plan.

Full mechanics: Bulgaria Tax Residency 2026: 183-Day Rule.

The double tax treaty does not save you here

The Germany-Bulgaria DTT prevents the same income from being taxed twice, but §6 AStG is an exit tax on unrealised gains at the moment of residency change. There is no corresponding Bulgarian tax on the same event, so there is nothing to credit. You just pay it.

The treaty does help afterwards: dividends from your Bulgarian EOOD to you as a Bulgarian resident are taxed at 5% in Bulgaria and not touched by Germany.

Timing: the calendar matters

Two dates control everything:

1. Residency end date. The day you deregister (Abmeldung) and lose unlimited tax liability. §6 crystallises here.
2. Bulgarian residency start date. When you become tax-resident in Bulgaria.

Get these wrong and you can end up dual-resident for a period, with both countries claiming you. Coordinate with a Bulgarian accountant and a German Steuerberater before you book the flight.

What a realistic timeline looks like

• Month -12 to -6: Set up Bulgarian EOOD, start routing new business, open banking.
• Month -6 to -3: Substance build. Board minutes, Bulgarian office, real presence.
• Month -3: Steuerberater prepares §6 valuation and instalment application.
• Month 0: Abmeldung, arrive in Bulgaria, register with Bulgarian tax authority.
• Month +12: First Bulgarian tax return filed. First §6 instalment paid to German tax office.

Rushing this is where people get hurt.

When the numbers do not work

If your GmbH is worth €5,000,000 and your acquisition cost is €25,000, your exit tax is roughly €1,460,000. You need a plan for that money before you move. Options:

• Sell to a third party while still German-resident (pay Teileinkünfteverfahren on the sale, but you have the cash).
• Restructure into a holding to spread the impact (complex, needs a lawyer).
• Stay and pay German taxes.

There is no clever move that makes a large Wegzugsteuer bill go away.

Next steps

Wegzugsteuer is a specialist area. A generic tax adviser will not know all the reform details. Work with a Steuerberater who has done exit-tax filings, and pair them with a Bulgarian accountant who understands the substance and residency side.

We can help set up the Bulgarian EOOD and coordinate with your German adviser. Book a free consultation to talk through your specific situation.

Related reading:

• Germany GmbH vs Bulgaria EOOD tax comparison
• Bulgaria tax residency: 183-day rule
• Bulgaria's 5% dividend tax explained
• Complete Bulgaria company formation guide

FAQ

Can I avoid Wegzugsteuer by moving to Bulgaria and back to Germany?

No. The tax crystallises on the day you leave. Coming back does not undo it; it can trigger a step-up if you sell later, but the original assessment stands.

Does §6 apply if I own less than 1% of the GmbH?

No. The 1% threshold is measured at any point in the five years before the move. Below that, no exit tax on the shares.

Can I gift shares to my Bulgarian-resident child before moving?

Gifting to a non-resident is itself an Ersatztatbestand that triggers §6. Do not try this as an avoidance strategy.

How is fair market value determined?

Usually via the German simplified valuation (vereinfachtes Ertragswertverfahren) or a full IDW S1 valuation. Your Steuerberater will handle it. Expect a professional valuation to cost €3,000 to €10,000.

Is the seven-year instalment plan interest-free?

The current instalment plan is not automatically interest-free the way the old EU deferral was. Interest may apply, and security is required. Discuss with your Steuerberater.