An interesting "hack" I discovered is to return to Germany within 1-2 years. By doing this, simply put, you don't pay any exit tax, since you submit your tax return with your exit tax practically at the same time as your return.

An interesting hack I discovered consists of returning within 1-2 years. This results in relatively little bureaucracy overall and, simply put, you pay no exit tax. This is because you declare your departure and your exit tax only within the scope of your normal income tax return for a specific year. And you only have to submit that in the following year or even more than a year later (with the corresponding deadlines).

So if, for example, you move away on Dec 31, 2025, you only have to submit this with your 2025 income tax return. If you do your tax return with a tax advisor (which is highly recommended here anyway), you have until March 1, 2027 (!) for the 2025 tax return. So you could live abroad for the entire year of 2026, pay no taxes in Germany, and then come back in February 2027.

Theoretically, exit tax would of course accrue since you moved away on Dec 31, 2025. However, since you have returned in the meantime, the tax will be refunded to you.

It is not entirely clear to me how the procedure works in practice, but I suspect that your tax advisor simply explains to the tax office that although exit tax would apply, you are now back. The "worst" that could happen to you here would be that you 1) still have to value your company shares to calculate the exit tax (€5k / company tax advisor costs) and 2) possibly have to pay deferral interest for that one year.

Whether that is really the case in practice, I do not know - perhaps there is a less complicated solution that your tax advisor can agree upon with the tax office. Unfortunately, there are very few tax advisors who have gone through this exact scenario, so it was difficult to find out how it works.

Who is this solution suitable for?

The biggest uncertainty here lies in the concrete implementation, for which I unfortunately found no testimonials. So how does communication with the tax office work in practice, especially upon return? Does your tax advisor simply say "the client is back" - do you then still have to have your companies valued and pay the theoretical exit tax, even though it is refunded to you immediately? And what about the deferral interest, do you have to pay that too?

These are questions to which I unfortunately found no answers in my research. Furthermore, the number of tax advisors who have gone through this seems to be extremely low - understandable, since the number of clients doing something like this is already low.

However, it is certain that it would work - the refund of the exit tax is guaranteed in any case, it will just depend on the details (company valuation yes/no, paying deferral interest yes/no etc.). The most important thing here is probably to find a tax advisor who has already gone through this specific case.