Anyone moving permanently to Georgia makes not only a life decision but also a tax decision. Before Georgia's location advantages take effect, the exit from the home country needs to be handled cleanly. This article explains the key pitfalls – above all exit taxation – and why sequence and planning are decisive.
Moving is more than packing bags
Moving to Georgia does not begin, for tax purposes, in Tbilisi but in the home country. Germany and Austria do not simply let their taxpayers leave: both countries have a so-called exit taxation that can apply when you leave. Anyone who ignores this risks nasty surprises – in the worst case a tax burden on gains that were never realised.
Precisely for that reason: moving to Georgia should be planned before it is carried out. The SOLO account and Georgian residency are the second half of the story – the first is a clean farewell from the old tax status.
German exit taxation (§ 6 AStG)
For German taxpayers, § 6 AStG is the central point when moving to Georgia. The provision assumes, on departure, a sale of shares in corporations at fair value – even though not a single euro flows. The hidden reserves are taxed as if the shares had been sold on the day of departure.
| Feature | § 6 AStG (as of 2026) |
|---|---|
| Who is affected | a holding of at least 1% in a corporation (private assets) |
| Prior history | at least 7 of the last 12 years unlimitedly tax-liable |
| Consequence | deemed disposal at fair value, taxation of the hidden reserves |
| Payment | since 2022 no more interest-free deferral; instalments over 7 years |
Important: Georgia is not an EU/EEA state. The unlimited, interest-free deferral once possible for EU moves was abolished anyway with the 2022 ATAD implementation act – when moving to Georgia as a third country, what regularly remains is the instalment payment over seven years, often against security.
§ 6 AStG is highly complex and case-dependent. This article serves orientation and does not replace tax advice. CMC is not a tax adviser; tax support is coordinated via team and network.
Austrian exit taxation
Austria too taxes hidden reserves in holdings when moving to Georgia. For moves to EU/EEA states there was the concept of non-assessment; for a third country like Georgia, the tax is in principle assessed – with the option to pay it in instalments over several years for certain assets. The details have shifted over the years, which is why a current case-by-case review is indispensable here too.
Extended limited tax liability (§ 2 AStG)
An often-overlooked point when moving to Georgia: departure does not necessarily end your tax history in the home country. Via extended limited tax liability (§ 2 AStG), Germany can still reach certain domestic income for up to ten years if substantial economic interests remain in the country. Anyone who wants to leave cleanly must know and deliberately shape these anchor points.
Sequence and substance
A successful move to Georgia follows a clear logic: first clarify the tax side in the home country (holdings, hidden reserves, reporting obligations), then build Georgian residency and underpin it with real substance – residence, presence or the requirements of the HNWI programme. A mere "letterbox emigration" does not hold and is recognised by the tax authorities.
Plan the move to Georgia with lead time. Anyone holding shares ideally clarifies § 6 AStG long before the move – sometimes the burden can be significantly reduced through foresighted structuring. After the move, the room for manoeuvre is usually smaller.
Interplay with the account
Once the tax side is clarified, the SOLO account at Bank of Georgia becomes the practical base of the new centre of life: liquidity on the ground, multi-currency capability and – if needed – a securities depot. Thus the move to Georgia comes together as an overall picture of legal status and functioning infrastructure. More on residency itself in the article tax residency in Georgia.
Conclusion
The move to Georgia is quite doable – but not a tax autopilot. Exit taxation (§ 6 AStG or the Austrian equivalent), extended limited tax liability and Georgia's third-country status need to be thought through in advance. Anyone who plans in the right order and creates real substance can use Georgia's advantages with legal certainty. CMC is not a tax adviser but coordinates the necessary expertise via team and network – and provides the base on the ground with the SOLO account.
Putting the tax pitfalls of relocation in perspective
Anyone moving from Germany or Austria to Georgia should plan the relocation carefully not only under residence-registration rules but also for tax. The key question is when unlimited tax liability in the home country ends – usually with giving up residence and habitual abode. Only after that does the territorial logic of the Georgian system apply, which generally does not tax foreign income.
For shareholders of corporations, leaving can trigger German exit taxation under section 6 of the Foreign Transactions Tax Act once a holding of at least one percent is held. Since 2022 the interest-free deferral no longer applies; the assessed tax is payable in instalments over seven years. Extended limited tax liability under section 2 can also have after-effects for up to ten years when relocating to a low-tax country. These points are strictly case-specific.
In practice, order and timing decide everything. De-registering your residence, establishing your centre of life in Georgia – via a residence permit combined with the 183-day rule or via the HNWI programme – and structuring existing holdings all interlock. CMC is not a tax adviser; for a binding assessment of your case you should engage qualified tax advice in your home country.
Relocating to Georgia: the key building blocks
Relocating to Georgia is more than a move – for tax purposes it turns on whether the residence and centre of life in the country of origin are actually given up completely. Anyone who keeps their German or Austrian residence generally remains subject to unlimited taxation there, regardless of how many days they spend in Georgia.
When giving up a substantial stake in a corporation, German exit taxation under § 6 AStG applies: hidden reserves are deemed realised and taxed, even without an actual sale. Since the reform there is no longer an interest-free, open-ended deferral; in many cases payment in instalments over seven years is provided. These consequences belong on the table before any departure.
Account first, residence separately
An account at Bank of Georgia can be opened independently of relocation and is often the first practical step. The actual relocation of residence is to be kept separate and needs qualified tax support. CMC is not a tax adviser; the organisational account opening and the tax planning of a departure are two different matters.
Frequently asked questions about moving to Georgia
What is exit taxation under § 6 AStG?
A provision that, on leaving Germany, assumes a deemed sale of shares in corporations (from a 1% holding) and taxes the hidden reserves – even without an actual sale. It applies if you were unlimitedly tax-liable for at least 7 of the last 12 years.
Is there a deferral when moving to Georgia?
The interest-free deferral once possible for EU/EEA moves was abolished in 2022. As Georgia is a third country, what regularly remains is the instalment payment over seven years, often against security.
Does my tax liability end with the move?
Not necessarily. Via extended limited tax liability (§ 2 AStG), Germany can reach certain domestic income for up to ten years if substantial economic interests remain in the country.
Is a Georgian residence on paper enough?
No. Both Georgian residency and the exit from the home country require real substance. A mere letterbox solution does not hold and is recognised. CMC is not a tax adviser and checks feasibility honestly with you.