Moving to Dubai from Germany

Germany is one of the most demanding countries to leave from a tax point of view, and the absence of a tax treaty with the UAE makes the details matter even more. With the right plan, many German entrepreneurs relocate to Dubai successfully, but the plan has to come first.

At a glance

• Tax treaty: the Germany-UAE double tax agreement has not applied since the end of 2021, so there is no treaty tie-breaker if both countries claim you.
• Ending German residence: you need to give up your German home and your habitual abode. Deregistering alone is not enough.
• Exit tax: shareholdings of at least 1% can be taxed on departure as if sold, if you were fully taxable in Germany for at least 7 of the last 12 years.
• Extended limited liability: German citizens moving to a low-tax country can remain taxable on more German income for up to 10 years if they keep substantial economic interests in Germany.
• Inheritance and gift tax: German citizens remain within German inheritance tax for 5 years after leaving, and longer in some low-tax situations.

Leaving Germany properly

Without a treaty, German residence is decided only by German law. If you keep an apartment you can use, or spend long periods in Germany, you may stay fully taxable there. Plan where you will live, what happens to your German property, and how often you will return.

Shares in a German company

The exit tax treats your shares as sold at market value on the day you leave, even though you receive nothing. For owners of valuable GmbH shares this can be significant. Payment can sometimes be spread over several years. Restructuring before the move, rather than after, is usually where the room to plan lies.

Building the UAE side

A UAE company needs real substance in the UAE, with management and decisions taken there. Otherwise Germany may treat the company as managed from Germany, or apply its rules on controlled foreign companies. We coordinate with your German tax adviser so both sides of the move match.

How Imperial Group helps

• A review of your residence position before you move, so you know when your home-country tax exposure actually ends
• The right UAE structure for your business: free zone, mainland or a holding company, with real substance
• Company setup, visas, Emirates ID and bank account opening support
• UAE tax residency certificate, corporate tax and VAT registrations from day one
• Ongoing accounting, tax filings and a single point of contact for everything in the UAE

Sources

• SKW Schwarz: Tax aspects of moving from Germany to Dubai
• Crowe: Discontinuation of the Germany-UAE tax treaty

This page gives general information as at the date shown and is not advice for your specific situation. Rules in other countries are summarised for orientation; your home-country position should be confirmed before you act.