[gndk]

> Pay taxes as if you had sold, even if you keep ownership. Which if you think about it, makes some sense.

It does make some sense, yea. The draconic thing is taxing you on a fictitious sale. I wouldn't have a problem with it if it was delayed until you actually sell the shares. There are actually ways to delay it, but they require a collateral.

For example if you can reasonably prove that it is a temporary absence up to 7 years when moving outside the EU, you don't have to pay the exit tax, but need to have collateral.

If you move inside the EU, the exit tax actually clashes with the EU's free movement directive and I think there are pending court cases for this up to high levels.

So if you move within the EU, you can delay indefinitely without interest, but they will still require a collateral. And if you want to leave Germany, you'll usually also want to leave the EU for the same reasons...

Switzerland is an option because due to various bilateral agreements, it is treated similarly as other EU countries.

Its funny that you mention this Canadian departure tax on stock holdings. Because just a few weeks ago the German government actually enhanced the exit tax and it now also applies if you own more than 1% OR 500k€ in a _single_ investment fund.

Supposedly this is to close loopholes around creating family-owned investment funds to get around the exit tax.

But as we all know, once a new tax is there, it will never go away. Easy enough to lower the limit or apply it to all holdings in the future.

[tharkun__]

Not just stock holdings. Any investments. Except for your primary residence, if you sell it before leaving. So e.g. you're not safe just because you didn't own stock and instead created a real estate investment empire :) If you keep your primary residence and rent it out for example (presumably because you do want to come back and retire in Canada?), then capital gains will accrue from the date you leave Canada.

Fictitious sale = deemed disposition. Same thing. If you can't pay the tax from cash you have lying around you will have to actually sell some of the investments.

Now I do get that selling a business might not be as easy as selling (part of) a liquid stock. But take the real estate example again. Selling your real estate empire seems much harder than selling some of your NVDA shares to pay the tax. If you aren't prepared to sell your business though and you want to hold onto it, why would the government be inclined to believe that you really want to leave and never come back so to speak?

[gndk]

> If you aren't prepared to sell your business though and you want to hold onto it, why would the government be inclined to believe that you really want to leave and never come back so to speak?

No idea. And for a corporation (GmbH) in Germany, it would actually be trivial to track and control this, since the ownership transfer is only possible through a notary public and only becomes legal fact after its published in the public company register. So put a flag on it, and when that transfer shows up, just block it until the exit tax from when you left is paid.