Year-End Exit Tax and Cyprus: Why Anyone Leaving on 31 December Must Assess Now

Status as of 18 October 2026: based on § 6 and § 2 of the German Foreign Tax Act (AStG) as published on gesetze-im-internet.de, the BMF form on the application of exit taxation dated 12 December 2025, Anlage WA-ESt for foreign-related returns, § 17 of the German Income Tax Act (EStG), § 17 of the German Federal Registration Act (BMG), Law 244(I)/2025 and the Cyprus Tax Department's residence guidance, the Germany-Cyprus double tax agreement of 2011, and the parallel official pages cited under Sources. We will update this guide when the statutes or the published practice change.

If you are still planning to leave your home country for Cyprus on 31 December 2026, or on 31 December 2027, the useful work is not a packing list. It is a tax assessment that should already be on the desk in October. Unlimited tax liability ends on a day. Share valuations are fixed on that day. Instalment clocks, protective assessments and residence tests count from that day. A clean Cyprus year starts on 1 January. None of those clocks care that you are busy in November.

We have already surveyed how high-tax countries hold on after a move in Leaving a high-tax country for Cyprus. That piece is the map. This one is the year-end execution guide: why 31 December matters, what to finish between October and December, how the German exit-tax statute on shareholdings works when you need a deep model, how the parallel year-end traps look in the Netherlands, the United Kingdom, Belgium, France and Romania, and how a Cyprus residence year (183-day or 60-day) and Non-Dom fit a clean leave. For the day-by-day Cyprus calendar itself, use The Cyprus 60-day rule calendar.

Tax is a cost. The state is not your partner in this exercise. Plan the cost, document the leave, and do not invent comfort that the statute does not give you.

Why 31 December is not a soft date

Most European tax systems run on the calendar year for individuals. Unlimited liability, residence, day counts and many valuation rules are tested inside that box. A departure dated 31 December therefore does three things at once.

First, it ends the home-country year of unlimited liability on a single day. That day is the valuation date for many exit-tax and protective-assessment rules. A shareholding worth X on 30 November and Y on 31 December is valued for the exit on the later figure if that is when unlimited liability ends. Advisers who need a valuation report, a bank statement pack and a company balance sheet cannot produce them in forty-eight hours.

Second, it starts the first Cyprus tax year on the next morning. Cyprus residence under the 183-day rule or the 60-day rule is measured from 1 January to 31 December. A move on 31 December 2026 with a home, a directorship and a day plan ready for 2027 is a clean start. A move that leaves the Cyprus file half-built into January is a year that has already started without you.

Third, it stacks paperwork that other offices only process while you are still on their books. Deregistration from the population register, a final return for the year of departure, health-insurance termination, pension address changes and company place-of-management questions all prefer a defined leave date and a forwarding address. The later you leave the assessment, the more of those offices you face from abroad with weaker leverage.

That is why October is the month to assess, not the month to "start thinking". For a 31 December 2026 leave you have about ten weeks. For a 31 December 2027 leave you have a full planning year, which is the better shape for anyone with a material shareholding.

A year-end leave also interacts with filing deadlines that sit in the following year. The home-country return for the year of departure is usually due in the spring or summer after you leave. The exit-tax assessment may arrive months after that return. Instalment one is then due within a month of the assessment, not within a month of the flight. People who treat 31 December as the finish line discover in May that the expensive work is still ahead. Budget cash for the first instalment and for adviser fees in the year after departure, not only in December.

Finally, banks and brokers will ask for a tax-residence self-certification when your address changes. A Cyprus TIN and, when you have it, a tax residence certificate support that file. The first Cyprus return cycle after you become resident is its own calendar; see the practical notes in Cyprus tax return deadlines and do not confuse that filing with the home-country exit return.

The October to December checklist for a year-end leaver

The list below is an execution order, not a substitute for advice in your home country. Swap the German labels for your own offices where the statute is different; keep the sequence.

1. Decide the leave date in writing

Write the intended move-out day, the city you leave, the Cyprus address you will use, and whether the plan is 31 December 2026 or 31 December 2027. Everything else hangs on that sentence. Soft dates produce soft filings.

2. Inventory every shareholding and fund interest

List each company in which you hold, or held in the last five years, at least 1% (the German § 17 EStG threshold that feeds § 6 AStG), every substantial participation under your home rules, and every investment fund share that your home country treats as a deemed disposal on emigration. For each line: acquisition date, acquisition cost, current fair value estimate, percentage, and whether the company is resident in your home country or abroad.

3. Commission the valuation that the leave date will need

Exit tax and protective assessments use fair value on the day unlimited liability ends. Unlisted shares need a method (earnings, net assets, recent transaction) that your adviser can defend. Public shares need a closing price source you can cite. Do this in October or early November, not in the last week of December.

4. Map your home and your family

A home you can still use often keeps unlimited liability alive even after you sleep elsewhere. Family that stays behind can keep a centre of vital interests argument alive under a treaty tie-breaker. Decide what happens to the flat, the lease, the school and the spouse's residence before you book flights.

5. Fix the company place of effective management

If you are a director or the mind of a home-country company, moving your own residence without moving how and where the company is managed can leave the company taxable at home, create a permanent establishment debate, or both. Board minutes, signing authority and where strategic decisions are taken need a plan that matches your leave date. Cyprus company formation, if that is part of the structure, belongs in this window: see Cyprus company formation.

6. File the population deregistration on time

Under German law, § 17(2) BMG requires deregistration with the Meldebehörde within two weeks after moving out, and at earliest one week before. Other countries have their own register rules. The certificate is evidence for the tax office, the broadcaster levy, banks and insurers. Keep it forever.

7. Notify the tax office of the departure

Do not assume the population register tells the tax office everything it needs. Send the move-out date, the Cyprus address, your tax identification number and the deregistration certificate. In Germany that is typically a letter or an ELSTER message to the Wohnsitz-Finanzamt, with Anlage WA-ESt on the year-of-departure return covering foreign facts and the shareholding questions.

8. Build the Cyprus file for 1 January

For a clean next calendar year you want, before or as the year opens: a permanent home in Cyprus (owned or rented), a business, employment or directorship in a Cyprus-resident person that will not be terminated during the year, and a day plan that either clears 183 days or meets the four 60-day conditions. The 60-day calendar explains why a late-2026 start often cannot rescue 2026 itself.

9. Sequence Non-Dom after residence, not before

Cyprus Non-Dom (0% special defence contribution on dividends and interest until you have been Cyprus tax resident for 17 of the last 20 years) follows from being Cyprus tax resident without a Cyprus domicile under the local rules. It does not replace an exit assessment at home. See Cyprus tax residency and Non-Dom.

10. Keep an evidence folder from day one

Boarding passes, lease, Abmeldebestätigung or equivalent, tax letters, valuation report, board minutes, and a day-count spreadsheet. December leavers who rebuild the file from memory in March lose arguments they did not need to lose.

11. Update banks and brokers with the new residence

CRS self-certification, new address, and, when available, the Cyprus tax residence certificate. Some products are restricted for non-residents of the old country; ask in writing before you assume the account survives unchanged. Operational banking after a move is its own subject: offshore banking operations. Do not confuse a working IBAN with a finished exit-tax file.

German § 6 AStG in depth: the model statute for share exit tax

We use the German rule as the deep model because it is precise, heavily litigated and the statute most often decisive for founders who hold at least 1% of a company. If your home country is not Germany, read this as the template of questions your own adviser must answer: who is caught, what is valued, when is it due, can it be spread, and what cancels it.

Who is caught

§ 6 AStG treats the end of unlimited income tax liability, caused by giving up residence or habitual abode, as a deemed disposal of shares within the meaning of § 17(1) sentence 1 EStG, at fair value (gemeiner Wert). The person must have been unlimited liable for at least seven of the twelve years before that event. The shareholding that § 17 catches is a participation of at least 1% in a capital company, held directly or indirectly at any time in the last five years. Foreign companies count. The same deemed-disposal logic also covers certain gratuitous transfers to a non-unlimited person and certain exclusions or restrictions of Germany's taxing right.

If you have never held 1%, § 6 on shares is usually not your problem. If you held 1% for a month four years ago and diluted later, check the five-year look-back with an adviser before you assume you are clear.

What is taxed

The gain is the fair value on the day unlimited liability ends, minus the acquisition cost as determined under § 17. The tax is computed under the partial income method that applies to § 17 gains. The law then treats the shares as acquired at fair value going forward only to the extent the exit tax has been paid; otherwise the old cost basis continues for German purposes. That sentence matters for later sales and for anyone who plans to return.

Fair value for an unlisted company is not a mood. German law takes fair value from sales between unrelated parties within the last year where they exist; otherwise from earnings prospects or another recognised method a buyer would use, and never below net asset value (§ 11(2) of the Valuation Act, BewG). A one-page spreadsheet with a round number and no method statement is how disputes start. If the company distributed large dividends in the years before departure, or if a sale process is already under way, say so in the valuation pack. The same facts that raise the exit value may also interact with the one-quarter distribution rule during the instalment period.

Investment fund units have their own exit rule. Since the Annual Tax Act 2024, § 19(3) of the Investment Tax Act treats leaving Germany as a sale of privately held fund units at fair value if you held at least 1% of the fund's units in the last five years or your units cost at least EUR 500,000, and it applies the § 6 AStG instalment, return and reporting rules. Put funds on the same October list even when they are not § 17 shareholdings. The BMF form of 12 December 2025 covers notifications under both provisions.

Seven instalments, security, and the 31 July clock

Since the 2022 redesign there is no open-ended interest-free deferral inside the EU of the old kind. Under § 6(4) AStG the assessed tax on the deemed gain can, on application, be paid in seven equal annual instalments. Security is the rule. The first instalment is due within one month of the assessment notice; the later instalments fall due each 31 July. The instalments are interest-free while the schedule is respected.

The unpaid balance becomes due within one month if an instalment is missed, if the reporting duties under § 6(5) are breached, if insolvency is filed, if the shares are sold or transferred, or if distributions or capital repayments exceed one quarter of the exit value. Death transfers between natural persons have a specific carve-out; do not generalise it.

Annual reporting: the BMF form

§ 6(5) requires electronic filing, on the official dataset, of any reportable event within one month, and an annual confirmation by 31 July of your current address and that the shares are still attributable to you (or to the successor in a § 6(1) sentence 1 no. 2 case). The BMF published the current form for the application of exit taxation on 12 December 2025. The statute requires electronic filing on the official dataset, but that BMF letter states the electronic interface is not yet finished and requires the published form until it is; the BMF expected the fillable form in its online form system from 1 January 2026. Check which channel is live before your first 31 July. The statutory paper route for hardship on application remains. Missing the 31 July confirmation is how unpaid instalments accelerate.

Return within seven years, extendable by five

If the absence was only temporary and you become unlimited liable in Germany again within seven years, the tax claim can fall away under § 6(3), provided the shares were not sold, transferred or contributed to a business, distributions and capital repayments stayed within the one-quarter limit, and Germany's taxing right is restored at least to the old extent. The competent Finanzamt can extend the return window by up to five further years on application if the intention to return continues. Returning is a plan with conditions, not a slogan.

What to do with this in October

1. Confirm whether any line on your inventory is a § 17 shareholding in the five-year window.
2. Confirm the seven-of-twelve unlimited-liability history (and any predecessor periods on gifted shares).
3. Get a fair-value estimate dated toward the planned leave day.
4. Ask the adviser whether to apply for seven instalments in the return itself, and what security the office will accept.
5. Diary 31 July for every year of the instalment plan before you leave.

Offer every German-law conclusion to a German tax adviser for review before you file. This guide is coordination and sequencing, not a substitute for that review.

German § 2 AStG: when a preferential regime keeps a longer German hand

§ 6 is the share exit tax. § 2 AStG is a different tool: extended limited liability for ten years after the end of the year of departure.

It can apply to a natural person who, as a German national, was unlimited liable for at least five of the ten years before unlimited liability ended, who is resident in a low-tax territory (or not resident anywhere), and who keeps essential economic interests in Germany. Low taxation includes a general rate more than one third below the German comparison at a statutory income of EUR 77,000, or a preferential regime that can reduce the burden substantially, unless the person proves that the total tax paid is at least two thirds of what unlimited German liability would have produced. For Cyprus, plan on the low-tax condition being treated as met. On our computation the general Cyprus scale for 2026 is not more than one third below the German one at EUR 77,000 (about EUR 15,250 against about EUR 21,204), so the live limb is the preferential regime. The German tax administration reads that limb abstractly: it is enough that the state of residence offers a special regime tied to residence or domicile status, whether or not you claim it, and it names the UK non-dom remittance basis as an example (BMF principles on the Foreign Tax Act of 22 December 2023, para. 23). Cyprus Non-Dom has the same shape. Your way out lies in the facts, not the label: no essential economic interests in Germany, extended German income of EUR 16,500 or less in the year, or proof that your total tax is at least two thirds of the German comparison. The Germany-Cyprus treaty takes priority over § 2 and still caps what Germany may collect on many income types (same BMF principles, para. 7).

Essential economic interests exist, among other cases, if at the start of the year you are an entrepreneur or co-entrepreneur of a German trade business (with a special rule for limited partners), or you hold a § 17 participation in a domestic capital company, or your German-source income (in the § 34d sense inverted) is more than 30% of your total income or more than EUR 62,000, or your German assets whose income would not be foreign under § 34d are more than 30% of your total assets or more than EUR 154,000. The whole of § 2 applies only in years where the extended limited income exceeds EUR 16,500.

For a year-end leaver the practical point is simple: if you will be Cyprus Non-Dom and you still have a German GmbH, German rent, or large German assets, have § 2 checked in the same October memo as § 6. Disclose the foreign low-tax / preferential facts on Anlage WA-ESt as the form requires. Do not assume that ending unlimited liability ends every German claim on every euro. Inheritance and gift tax runs on its own clock. A German national who leaves without keeping a German home stays fully liable to German inheritance and gift tax on worldwide assets for five years (§ 2(1) no. 1(b) ErbStG). Cyprus levies no inheritance tax and Germany has no inheritance tax treaty with Cyprus, so nothing offsets that claim. In years six to ten, if § 2 AStG applies at the time of a death or gift, § 4 AStG extends limited German inheritance tax to every part of the transfer whose income would not be foreign income.

The Cyprus side of a clean year-end leave

Cyprus does not cancel your home country's exit tax. It receives you under its own residence rules. The leave is clean when both clocks are designed together.

183-day versus 60-day for the next calendar year

Under Law 244(I)/2025, in force from 1 January 2026, an individual is a resident of the Republic for a tax year either by spending more than 183 days in Cyprus in that year, or under the 60-day rule. The 60-day rule has four cumulative conditions for the tax year: at least 60 days in Cyprus; not more than 183 days in any other single state; a permanent home in Cyprus owned or rented; and a business, employment or office in a Cyprus-resident person at any time in the year, not terminated during the year. Day counting for Cyprus days is fixed in the law: arrival counts, departure does not; same-day arrival and departure counts as one Cyprus day.

If you have already spent more than 183 days in one other state in 2026, the 60-day rule is closed for 2026. That is arithmetic, not opinion. The execution answer for most October readers is a clean 2027: home, activity and day plan in place for 1 January 2027. The calendar article walks the dates. The older myth piece remains useful for what the rule is not: 60-day Cyprus tax residency myths.

Non-Dom after residence

Once you are Cyprus tax resident and not domiciled in Cyprus under the local domicile rules, Non-Dom gives 0% special defence contribution on dividends and interest. It ends once you have been Cyprus tax resident for 17 of the last 20 years, when you become deemed domiciled. GESY contributions still apply (2.65% on the relevant bases for employees, pensioners, dividends and interest, with the published cap). Non-Dom does not erase exit tax at home and does not turn every foreign structure into a dividend. Transparent foreign income is a separate analysis.

Company and management

A Cyprus tax-resident company (15% corporate income tax from 1 January 2026) can be the vehicle for the office condition under the 60-day rule and for post-move operations. Place of effective management, substance and the home-country permanent establishment risk must be designed with the leave date, not after it. Our relocating to Cyprus sequence, the guide to international company structures, and the Cyprus as EU Plan B base piece sit beside this guide. For the multi-year Non-Dom and citizenship horizon after the first clean year, see Cyprus for the long run. Cost of living for the household budget belongs in the same October pack as the exit valuation: cost of living in Cyprus 2026.

Treaty overlay

The Germany-Cyprus agreement of 2011 is the model many readers will meet: residence tie-breaker, taxing rights on dividends, pensions and immovable property. Other home countries have their own treaties with Cyprus. Exit tax is domestic law; the treaty decides residence conflicts and source taxing rights. Run both.

Parallel year-end notes outside Germany

These notes are short on purpose. They flag the year-end trap; they do not replace the country chapters in the exit-side survey.

Netherlands: protective assessment

If you emigrate from the Netherlands, the Belastingdienst may issue a protective assessment (conserverende aanslag) after the return for the year of emigration. Pensions and annuities with past Dutch relief typically carry a deferral of up to ten years if you keep the Dutch rules; for a substantial shareholding (aanmerkelijk belang) in a Dutch company, anyone deregistered after 15 September 2015 gets a lifetime deferral with no remission after ten years, so the claim never lapses. Moves to an EU or EEA state get automatic, interest-free deferral; moves outside the EU or EEA can require security. Trigger events (commuting a pension, surrendering an annuity, selling the shares, certain dividends, company cessation) make the assessment payable. Diary the emigration-year return and the deferral conditions before 31 December.

United Kingdom: Statutory Residence Test and split year

The UK taxes by the Statutory Residence Test. Leaving mid-year can qualify for split-year treatment only in defined Cases (full-time work overseas, accompanying a partner in that situation, or ceasing to have a UK home, each with strict conditions and a priority order). A 31 December leave sits awkwardly against a UK tax year that runs to 5 April: count UK days, the automatic tests and the UK ties carefully for 2025/26 and 2026/27. Split year is not automatic. Use HMRC RDR3 with a UK adviser.

Belgium: capital gains and deemed disposal on leaving

Belgium's personal capital gains tax on financial assets applies from 1 January 2026. Leaving Belgian tax residence is treated as a deemed disposal of the relevant assets under that regime. For a move to an EU or EEA state, or to one of the few treaty states the Belgian circular lists, payment deferral is automatic; elsewhere, the UK and the US included, you apply and post security. The tax lapses if you keep the assets for 24 months after departure, with certificates due by the end of the 14th and 26th months. Keep the 31 December 2025 reference values and the departure-day inventory. The rates and substantial-participation bands are for a Belgian adviser to apply to your list; do not hard-code a rate from a headline.

France: article 167 bis

Article 167 bis of the French General Tax Code taxes unrealised gains on shareholdings when you transfer tax residence out of France, if you were French tax resident for at least six of the ten preceding years and you hold rights representing at least 50% of a company's profits or covered securities worth more than EUR 800,000 in total. For an EU destination such as Cyprus, payment is typically deferred, with ongoing reporting. Discharge after keeping the shares is commonly two years where the relevant value is up to EUR 2.57 million, and five years above that (confirm the threshold against the current BOFIP text for your year). A proposed fifteen-year holding period was not retained in the finance law for 2026 as finally adopted. Selling earlier can crystallise collection.

Romania: no individual exit tax, but the chestionar and residence

Romania does not levy a general exit tax on individuals when they leave. The trap is residence and reporting. On departure, the ANAF questionnaire for establishing the tax residence of a natural person leaving Romania (form Z017 and related guidance) is the practical filing to plan. It must be registered 30 days before you leave if you will spend more than 183 days abroad in any 12 months; for a 31 December leave, that means by 1 December. Romanian residence looks at domicile, the centre of vital interests and the 183-day presence test. A year-end leave that leaves the family home, the company and the day count ambiguous is how double claims start. File the questionnaire, keep proof of the Cyprus centre of life, and treat German or Dutch exit tax only as a comparison if you also hold those ties.

Worked cases (illustrative, not clients)

Case A: Founder with 40% of a home-country GmbH, leave 31 December 2026

Inventory in October shows a 40% stake acquired in 2019, book cost low, fair value high. Seven-of-twelve unlimited liability is met. § 6 applies on 31 December 2026 at fair value. The adviser applies for seven instalments and prepares security. Abmeldung is booked for late December; Finanzamt is notified; WA-ESt is queued for the 2026 return. Cyprus: lease from 1 January 2027, directorship in a Cyprus-resident LTD from January, day plan for either 183 or 60-day. Non-Dom filed in the first year with dividends. § 2 is checked because German-source income and the domestic shareholding may still be large. Result: exit cost known before Christmas, Cyprus year opens clean.

The October memo for Case A also fixes three operational points. First, the GmbH's place of effective management: either the company stays German-managed with the founder as a non-resident director under clear board rules, or management moves with a documented trail. Second, the banking self-certification: Cyprus address and TIN go to the German broker before the first dividend after departure. Third, the instalment diary: 31 July reminders for six years after the first payment, plus the annual § 6 electronic confirmation. None of those three is glamorous. All three are how Case A stays a planned cost instead of a surprise acceleration.

Case B: Consultant, no 1% holdings, leave 31 December 2026 from the Netherlands

No § 17-type stake. Dutch protective assessment risk sits on pension rights, not on shares. October work is the emigration-year return pack, the deferral conditions, and proof of Cyprus residence for 2027. UK split-year issues are irrelevant. The expensive mistake would be ignoring the pension protective assessment until a later commutation triggers payment.

Case C: Romanian SRL owner, family relocating for 2027

No Romanian exit tax on the shares at departure. October to December work is the ANAF departure questionnaire, closing or migrating the Romanian centre of vital interests, and a Cyprus 2027 residence file (home, activity, days). German § 6 is irrelevant unless there is also a German shareholding history. The comparison to § 6 is used only to explain to co-founders why a German partner in the same group faces a different bill.

How this pairs with a Chile Plan B

A Cyprus tax residence year solves the European base. It does not replace a second residence outside the EU if that is part of your Plan B. Chile's residence route is the sister article for today: Chile residence as Plan B. Sequence matters: finish the home-country exit assessment and the Cyprus year design before you stack a second file. Two half-built residences are worse than one finished leave.

If asset protection and privacy are part of the same redesign, keep them downstream of the exit assessment. Moving shares into a new holding structure in November without checking whether that transfer itself is a § 6 or home-country disposal event is a common way to create a tax bill you did not model. Read asset protection and privacy as a separate workstream, not as a shortcut around exit tax. For a lighter Plan B jurisdiction already in the series, Georgia residence shows the same sequencing discipline: exit and Cyprus first, second card second.

Common relocation myths (that a flight ends tax residence, that a company abroad has no home-country footprint, that Non-Dom is automatic) are collected in Cyprus relocation myths. This year-end guide assumes you have already discarded those.

Who this suits

• Founders and shareholders who already know they will leave on a year-end date and need the cost and the calendar in one memo.
• Households that can decide what happens to the home-country flat and the family ties before December.
• People willing to pay for a valuation and a home-country tax adviser in October, not in the week of the flight.
• Readers who will run Cyprus residence as a full calendar year, not as a Christmas holiday with paperwork.

Who this does not suit

• Anyone hoping that a 31 December flight alone ends home-country tax claims without deregistration, filings and valuations.
• Holders of material shareholdings who refuse instalment security or annual reporting after they leave.
• People who need the 60-day rule for 2026 after already spending more than 183 days in one other state this year.
• Anyone looking for a promise that Non-Dom cancels exit tax. It does not.

FAQ

If I leave on 31 December, which year is my first Cyprus tax year?

The next calendar year, if that is when your Cyprus residence conditions are met. A landing on 31 December 2026 with the 2027 file ready makes 2027 the first designed Cyprus year. Cyprus does not write home-country exit tax for you.

Does every shareholder pay German exit tax on the way to Cyprus?

No. § 6 AStG needs a § 17-type shareholding (at least 1% in the five-year window) and seven of twelve years of unlimited liability, among other conditions. Many movers have neither. Assess the inventory; do not assume the headline.

Can I pay German exit tax over time?

On application, yes: seven equal annual instalments under § 6(4), usually against security, with the first due within a month of the assessment and the rest each 31 July, plus the annual electronic confirmations. Breach the conditions and the balance accelerates.

Is Cyprus Non-Dom enough to ignore § 2 AStG?

No. Non-Dom can feed the preferential-regime limb of low taxation under § 2. Whether § 2 actually applies depends on nationality history, German economic interests and the income thresholds. Have it checked in the same memo as § 6.

What if my home country is not Germany?

Use the October checklist, read your country's short note above, and open the multi-country exit survey for the wider map. The German statute is the deep model, not a claim that every reader is German.

Sources

Primary and official sources, verified 18 October 2026:

• German Foreign Tax Act § 6 (exit taxation of share gains): https://www.gesetze-im-internet.de/astg/__6.html
• German Foreign Tax Act § 2 (extended limited liability): https://www.gesetze-im-internet.de/astg/__2.html
• German Income Tax Act § 17 (share disposals, 1% / five-year window): https://www.gesetze-im-internet.de/estg/__17.html
• Federal Registration Act § 17 (deregistration timing): https://www.gesetze-im-internet.de/bmg/__17.html
• BMF, form on the application of exit taxation / notification under § 6 AStG, 12 December 2025: https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Internationales_Steuerrecht/Allgemeine_Informationen/2025-12-12-vordruck-anwendung-wegzugsbesteuerung.pdf?__blob=publicationFile&v=1
• Anlage WA-ESt (foreign-related income tax schedule; year-of-departure facts): official income tax form set for the relevant year (ELSTER / BMF form portal)
• Germany-Cyprus double tax agreement 2011 (BMF publication PDF)
• Cyprus Income Tax Law 118(I)/2002, definition of resident of the Republic (CyLaw)
• Law 244(I)/2025 amending the Income Tax Laws, in force 1 January 2026: https://cylaw.org/nomoi/arith/2025_1_244.pdf
• Cyprus Tax Department, tax residency and domicile: https://www.gov.cy/mof-tax/en/documents/tax-residency-domicility/
• Dutch Tax Administration, protective assessment on emigration: https://www.belastingdienst.nl/wps/wcm/connect/en/individuals/content/protective-assessment-in-the-case-of-emigration
• HMRC, Statutory Residence Test guidance (RDR3): https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt
• HMRC RDR3, chapter on split year treatment (Cases 1 to 3 for leavers)
• French General Tax Code article 167 bis (Legifrance / BOFIP)
• ANAF, chestionar for tax residence on leaving Romania (Z017): https://static.anaf.ro/static/10/Anaf/Declaratii_R/Z017.html

Secondary commentary used only to locate primary texts: professional summaries of Belgian capital gains guidance from 2026 and of the French finance-law outcome on the proposed fifteen-year exit-tax holding period.

Verified on 18 October 2026. Hierarchy we rely on: first the statute text as published, then ministry forms and tax-administration guidance, then treaty texts, then professional commentary. Where they differ, the statute wins and we say so.

For a structured leave into Cyprus, start from the English blog hub. When you want the Cyprus file built beside your home-country adviser, use the contact page.

Cover photo: Mriana Agbaria, Wikimedia Commons, CC BY-SA 4.0, cropped.