From January 1, 2022 new rules for exit taxation 

As of 01.01.2022 the exit taxation (§ 6 AStG) has been reformed. Lose right to taxation in case of taxpayer's departure. Until 31.12.2021, every taxpayer who has been subject to unlimited tax liability in Germany for at least 10 years was subject to exit taxation. From shareholders in a family business to start-up entrepreneurs, every entrepreneur with a stake of at least one percent in a corporation (GmbH, AG) who wants to relocate his or her residence abroad is potentially affected.

NEW is that the period with regard to unlimited tax liability has been shortened from 10 years to 7 years. Taxpayers who have moved to Germany will be subject to exit taxation 3 years earlier - i.e. after 7 years. In addition, the deferral in the case of departure to an EU/EEA state has been abolished. Now the tax must be paid in 7 annual installments. As a result of these tightening measures, there is increasing pressure to think through the tax consequences carefully before moving abroad and to secure Germany's right to taxation through optimal tax structuring - despite the move - in order to avoid substantial tax payments.

Should taxation have been reduced or actually avoided at the time of departure, later inheritance tax consequences must also be considered. If the testator was resident abroad but the heirs are resident in Germany, German inheritance tax applies again. Here, too, it is important to examine all possible alternatives from a tax point of view in advance.