Wegzugs- Akte

German nationals who move abroad may remain subject to extended limited tax liability under § 2 AStG for ten years. This calculator checks the conditions and provides an indicative tax figure.

Extended limited tax liability — review and tax calculationAssessment period

Prefilled with a sample: airline pilot at Emirates, departure to the UAE. Overwrite all values.

A. Person and departure§ 2 (1) sentence 1 AStG

Client / file reference

German nationality

Years of unlimited tax liabilityin the ten years before departure, at least five

End of unlimited tax liability

B. Residence and taxation§ 2 (1) sentence 1, (2) AStG

Country of residence

Not resident in any foreign territoryLow taxation is then irrelevant — the comparison calculation does not apply.Resident — rate comparisonLow taxation if foreign tax on income of €77,000 is more than one third below the German tax.Resident — preferential regimeA privilege versus ordinary taxation that can substantially reduce tax. The legal possibility is enough.Resident — ordinary taxationNeither a rate gap nor a preferential regime.

Foreign tax on €77,000German comparison tax 2026: 21,204 €. Low taxation below 14,136 €.

Counter-evidence: tax actually paidNo low taxation if it reaches at least two thirds of the deemed German tax under unlimited liability. 0 = no counter-evidence.

Deemed German tax under unlimited liability

C. Substantial economic interests§ 2 (3) AStG

One of the three numbers is enough.

No. 1 — business or shareholdingEntrepreneur or co-entrepreneur of a domestic trade business, limited partner with more than 25% profit share, or a § 17 EStG shareholding in a domestic company. The size of the shareholding is otherwise irrelevant.

No. 2 — incomeNon-foreign income above 30% of all income or above €62,000. Calculated from block D.86.2 % / 112,500 €

No. 3 — domestic assetsAssets whose income would not be foreign income (market values under the BewG).

Total assets

D. Income of the assessment period§ 2 (1), (5) AStG

Column I: domestic income under § 49 EStG. Column II: additional income — everything that would not be foreign income under § 34d EStG if unlimited liability applied. Column III: foreign income that only affects the tax rate.

Description	Type	Allocation	Amount €

Result for 2026

Extended limited tax liability

All conditions are met. 112,500 € of non-foreign income is captured and taxed at the rate for worldwide income.

met
Person and prior liability
German national, 10 years of unlimited tax liability in the ten years before departure (required: five).
§ 2 Abs. 1 Satz 1 AStG
met
Ten-year window
Departure 2021; assessment periods 2021 to 2031 are covered. Checking 2026.
§ 2 Abs. 1 Satz 1 AStG
met
Residence and low taxation
Foreign tax on €77,000: 0 €, German comparison tax 21,204 €. Two-thirds threshold 14,136 € — undershot, low taxation.
§ 2 Abs. 2 Nr. 1 AStG
met
Substantial economic interests
No. 1 not met · No. 2 met (86.2 % of 130,500 €, non-foreign 112,500 €) · No. 3 met (380,000 € of 900,000 €)
§ 2 (3) AStG — one number is enough
met
Exemption threshold
Non-foreign income 112,500 € versus the threshold of 16,500 €. What matters are the income amounts actually subject to tax, including amounts taxed at a final withholding rate.
§ 2 (1) sentence 3 AStG, AEAStG paras. 20–22

Calculation

Column I — § 49 EStG: 14,400 €
Column II — additional income: 98,100 €
Tax base § 2 (1) AStG: 112,500 €
Column III — foreign income: 18,000 €
All income: 130,500 €
plus basic allowance (§ 50 (1) sentence 2 EStG): 12,348 €
Statutory tax thereon (§ 32a EStG 2026): 48,860 €
Special rate (§ 2 (5) AStG): 34.2 %
Income tax on 112,500 €: 38,479.71 €
For information: § 49 income only: 1,786.27 €
Additional burden from § 2 AStG: 36,693.44 €

Form ASt 1 A has no field for this

Additional employment income cannot be declared in the annex: in column II, lines 72, 73, 79 and 80 are barred, and lines 74 to 78 are not even subdivided into fields.

The form assumes employment income is either § 49 EStG (column I, usually with wage-tax withholding, see line 120) or foreign income under § 34d no. 5 EStG (column III). The third case — work performed abroad that is neither performed or exploited in Germany nor performed in a foreign state — is not provided for.

Declare the amount in a separate annex to column II and point to the barred lines.
Attach a computation under German law: gross pay, income-related expenses, places of work, allocation.
Line 120 does not apply — no wage tax was withheld.
The bar is a form design, not a restriction of § 2 (1) AStG. A departure from the form should be explained in the covering letter.

Law unchanged for 2025 and 2026: €16,500 threshold, comparison income €77,000, one-third and two-thirds limits, 30% / €62,000 for income, 30% / €154,000 for assets. Sources: § 2 AStG, § 34d EStG, AEAStG of 22 Dec 2023, BFH IX R 37/21, BFH I R 19/06, Rate under § 32a EStG. The tax figure is an estimate without special expenses, extraordinary burdens or solidarity surcharge; § 2 (6) AStG and any tax treaty must be reviewed separately.

Important: This tool provides a non-binding automated first assessment and does not replace tax advice. For a binding assessment, please book a meeting.