• You continue to pay German taxes on rental income as normal.

• Increase Managing Director salary from currently €60k / year to €120k / year. Since this would prospectively lower the annual profit of the company to near zero, this results in a very low company valuation. This would solve the problem of the German operative GmbH.
  It is also interesting that one could keep the low salary (€60k / year) and still apply a "virtual", market-standard salary (€120k / year) in the valuation. This is possible in the normal valuation procedure (simplified capitalized earnings method).
• There are also more exotic constructs (e.g., foundation), but we did not discuss them.
• How can I prospectively move the German GmbH abroad? Two options:
  • Option 1 (worse option): Found a foreign company and slowly shift revenues there, then eventually liquidate the German company. This runs the risk that the tax office looks at why the German company was liquidated even though it still has a website, etc. Technically, there should still be objects (assets) in the company.
  • Option 2 (better option): Found a foreign company and sell the assets of the German company to the foreign company. German GmbH remains in existence, e.g., to employ German staff.
    (Felix Becker from Juhn mentioned that such a deal might be looked at by the tax office, see below)
  • (I later learned that the best variant consists probably of simply letting the German GmbH exist and not shifting activities abroad - instead, one would build future companies, products, and services in a new foreign company after moving away. Should have the least potential for problems with the tax office; therefore the two proposed options here are perhaps not particularly optimal.)

• Easiest way is to simply have them valued and pay the exit tax. He has a contact who can perform the valuation.
  (It turned out later that I had estimated the valuation of the shares too low and a higher exit tax would therefore apply here - he could not know that. Assuming the shares had actually been worth as little as I initially thought, then this would have been a pragmatic approach.)

• Do I have to provide proof to the tax office that I also pay taxes abroad? --> He was not sure. He suspects that this might only be requested by the tax office if one pays out significant amounts from one's German GmbH to abroad, e.g., as dividends or as Managing Director salary. A better solution here would be to found a foreign company and sell the objects (assets) of the German GmbH there.
  (Interestingly, Felix Becker from Juhn Partner mentioned that such a deal then has a high probability of being looked at by the tax office, since one is basically transferring assets from one to the other as the owner of both companies.)
• Do I have to live in my destination country for 180 days until I have officially moved away from Germany? --> No, the date applies on which one gives up one's residence in Germany, i.e., on the date on which one terminates one's rental contract, cancels electricity and internet, etc. Theoretically, one could be in Germany for a while again afterwards, but one would not be allowed to sign a rental contract and especially not have "possession of keys" (Schlüsselgewalt).

Summary: Experience with Jost von Steegen