Germany vs Austria.

Listed shares

26.375% before church tax

A private listed-share gain normally uses 25% investment tax plus a 5.5% solidarity surcharge on that tax. A holding of at least 1% can move into the owner-company rules instead. The yearly saver allowance can shelter part of the gain.

Fund and ETF units

26.375% on 70% for a qualifying equity fund

A qualifying equity fund leaves 30% out of tax. The remaining 70% of its distributions, annual fund charge and sale gain enters the tax calculation. Other fund types use different percentages.

Holding period and allowances

No general long-holding relief; €1,000 saver allowance

Holding shares or fund units for longer does not reduce the rate. The saver allowance is €1,000 for one person and €2,000 for a couple filing jointly. The equity-fund exemption depends on the type of fund, not how long you hold it.

Losses

Share losses can offset only share gains

Investment losses can carry forward, but the category matters. A loss on a share disposal can offset only share-disposal gains rather than interest, dividends or every other capital return.

Foreign listings and US ETFs

Same German rate; source tax and fund type separate

A foreign listing does not change the German investment rate. A pure share-sale gain is usually taxed only where you live under the treaty. Tax already taken from dividends is a separate credit or reclaim. An ETF's fund type decides how much of its return is taxed.

Advance lump sum

Possible annual tax before you sell

A profitable fund can create a taxable amount when its cash distributions fall below a statutory return. The charge cannot exceed the fund's actual growth. Amounts taxed this way reduce the taxable gain when you eventually sell.

German-company dividend

26.375% before church tax

A German-company dividend normally has 25% investment tax withheld plus the 5.5% solidarity surcharge on that tax. The saver allowance can apply, and church tax can add a separate amount for members.

Foreign listed-share dividend

26.375% plus tax taken abroad

Germany applies the same investment-income rate to a foreign dividend. Tax taken abroad can reduce the German bill only as far as zero. Any excess needs treaty relief or a reclaim abroad.

Holding size and active owners

Default rate at any size; elective 60% method

The flat investment rate remains the default. An election can make 60% of a dividend taxable under the income-tax bands if the owner holds at least 25%. The same choice can apply from 1% when the owner also has a qualifying professional role.

Fund distribution

26.375% on 70% for a qualifying equity fund

A qualifying equity fund leaves 30% of its distribution out of tax. The remaining 70% enters the investment-income calculation.

New-resident treatment

No general new-resident exemption

Germany has no general new-resident exemption for foreign dividends. Tax on worldwide income starts with residence. Treaty relief can reduce double tax.

There is no separate rule here. Use the general foreign-income case, then check what the treaty says about the country paying the money.

Sale for fiat

Income-tax bands within one year; exempt after more than one year

A private sale within one year is added to your other taxable income. A qualifying sale after more than one year is exempt. The original purchase date still counts after a move.

Crypto-to-crypto exchange

Same private-disposal rule; new one-year clock

Exchanging one token for another is a disposal at market value. The acquired token starts a new one-year holding period and takes that market value as cost.

Spending

Same private-disposal rule

Using a token to buy goods or services is a disposal. Market value measures the proceeds, so the one-year period and €1,000 exemption threshold still matter.

Holding relief and losses

Exempt after one year; €1,000 short-term threshold

The former ten-year extension for lending or staking no longer applies. Losses within the private-disposal category can offset only gains in that category and follow their own carry rules.

Staking and lending rewards

Income-tax bands on receipt

Staking and lending rewards can be taxable income when received. This income category has a €256 yearly exemption. The value taxed on receipt becomes the new token's purchase cost and starts its one-year holding period.

Mining and airdrops

Income or business profit, then a later disposal

Mining or validation can be other income or a commercial business, depending on scale and organisation. An airdrop linked to a service can be income. Another airdrop can start with no purchase cost, which affects the gain when it is later sold.

Private or commercial activity

Business rules replace the one-year exemption

A private holder uses the private-disposal rule. A commercial token activity falls into business income, where the one-year exemption does not apply and trade tax can also arise.

Wealth and departure tax

No annual net-wealth tax or crypto exit charge

Germany has no current annual net-wealth tax. The individual exit-tax rule targets qualifying company shares, not an ordinary private crypto holding.

New-resident treatment

No new-resident rule; old holding time continues

Germany does not provide a new-resident crypto exemption. Original purchase cost and the original holding date continue after arrival, which can make a qualifying private sale exempt once the more-than-one-year test is met.

German statutory or company pension

Income-tax bands on the taxable portion

A German statutory pension is taxed on its statutory taxable share, which depends on the cohort. A company pension can instead be employment income. The personal rate follows the total taxable income.

Foreign state pension

Treaty and pension class control

A foreign state pension can be taxable in Germany, exempt with progression, or allocated to the paying state under the treaty. The exact pension article controls.

Foreign occupational or private pension

Income-tax bands on the taxable portion

Germany identifies the scheme type before calculating tax. A life annuity may tax only its income share, while an occupational payment can follow a different rule. The treaty then decides which country can tax it.

Government or civil-service pension

Separate treaty article

A government-service pension commonly remains taxable in the paying state, subject to the treaty's nationality exception. Where the treaty allows it, Germany can use an exempt pension to set the rate on the person's other income.

Lump sum

Exact foreign result not pinned

No single rate is pinned here for a foreign pension lump sum. The scheme type, contribution history and treaty must be checked before treating it like a periodic pension.

New-resident treatment

No general new-resident exemption

Germany does not provide a general special rate or exemption for a foreign pension merely because the recipient has just become resident.

Company profit

Often about 30% including trade tax

Corporation tax, solidarity surcharge and municipal trade tax together often produce a rate around 30–33%. A foreign company can also become German-resident when its main decisions are made in Germany.

German-company distribution

26.375% by default after company tax

A distribution comes from profit after company tax and then uses the owner's investment- income rate. A qualifying active owner can elect the 60%-taxable method instead.

Foreign-company distribution

German dividend tax plus tax taken abroad

A foreign-company dividend follows the same personal investment-income rules. Tax taken abroad and treaty relief remain separate. The exemption available to some company shareholders does not automatically pass to an individual owner.

Foreign entity classification

Classification before extraction rate

Germany compares the foreign vehicle with German legal forms to decide whether it is a company or transparent arrangement. That choice changes whether the resident has a dividend, direct profit or another category.

Owner threshold

1% within the previous five years is decisive

A person who held at least 1% at any point in the previous five years falls within the substantial-share disposal rule. The same threshold is central to the individual exit-tax regime.

Sale of the company stake

26.375% below 1%; 60% added to income at 1% or more

A portfolio stake below 1% normally uses the investment-income rate. A qualifying stake of at least 1% adds 60% of the gain to other taxable income and leaves 40% exempt. Leaving Germany can also treat the stake as sold and charge exit tax before an actual sale.

Salary or director pay

Income-tax bands up to 45% plus social contributions

Salary and director pay are employment income. Wage tax withholding and social insurance can apply, while the company's deduction and the owner's tax must be modelled separately.

Owner social-insurance status

Control and dependence decide

A managing shareholder is not automatically employed or self-employed for social- insurance purposes. A controlling owner is usually outside statutory social insurance, while a minority owner is usually inside. The exact status depends on the facts.

Running the company from Germany

German company tax can arise

Making the main company decisions from Germany can make the foreign company German-resident. A fixed workplace or an agent acting for the company can separately create a taxable German business presence.

CFC rules

Can tax foreign-company profit before a dividend

A German resident who controls more than half of a foreign company can be taxed on certain passive, low-taxed profit before it is paid out. The ownership, type of income and foreign tax rate all matter.

New-resident treatment

No general owner-company new-resident rule

Arrival does not switch off the rules for company residence, a taxable business presence, large shareholdings, exit tax or CFCs. Each has its own threshold and period.

German property rent

Income-tax bands on net income

German rent enters the ordinary income-tax bands after allowable expenses and depreciation. Financing, repairs and acquisition costs do not all receive the same timing.

Foreign property rent

Source tax plus treaty relief in Germany

The property's country normally taxes first. Many treaties exempt the foreign rental income in Germany but use it to set the rate on other income. Other treaties give a credit instead, so the country pair controls.

Deductions

Net income after allowed costs and depreciation

Interest, repairs, management and depreciation can reduce taxable rent when the statutory conditions are met. The exact depreciation rate depends on the building and completion date, so it is not reduced to one number here.

There is no separate rule here. Use the general foreign-income case, then check what the treaty says about the country paying the money.

Main home

Exempt when the self-use conditions are met

A home used exclusively by the owner can be exempt. A second route covers use in the sale year and the two preceding calendar years, subject to the statutory facts.

German investment property

Added to other income within ten years; exempt after

A private investment-property gain is added to your other taxable income if you sell within ten years of buying. After ten years, the qualifying private gain is exempt.

Foreign property

Property-country tax; treaty exemption or credit

The property's country normally taxes the gain. Germany may give credit for that tax. Another treaty may leave the gain out of German tax but use it to set the rate on other income. The German ten-year rule still needs to be checked.

Home exemption conditions

Continuous self-use, or sale year plus two prior years

The exemption can apply to continuous owner occupation or to qualifying use in the year of sale and both preceding calendar years. Letting and mixed use can leave part taxable.

Starting value after a move

Original purchase cost and original acquisition date

Germany does not reset property on arrival. Original purchase cost measures the gain and the original acquisition date continues the ten-year clock.

New-resident treatment

No general new-resident exemption

A recent arrival receives no separate property-gain exemption. The ordinary self-use, ten-year and treaty rules apply.

There is no separate rule here. Use the general foreign-income case, then check what the treaty says about the country paying the money.

German royalties

Personal income-tax bands

A passive licence can fall within rental-type income, while the creator's own professional work can be freelance income. Commercial licensing can instead be business income.

Foreign royalties

German income tax plus tax taken abroad

Germany taxes a resident's foreign royalty under its classified category. The source country may withhold, with the treaty providing exemption, credit or a reduced source rate.

Which rights qualify

Temporary licensing differs from a permanent transfer

A time-limited grant of copyright, patent or know-how can be a royalty. A permanent sale of the right can be a disposal instead, so the contract and retained rights matter.

Passive or active

Rental, freelance or business income

Passive licensing can remain rental-type income. An author or artist can be freelance and avoid trade tax, while a commercial operation can be a trade subject to municipal trade tax.

Social contributions and VAT

Active work can add both

Active creative work can bring VAT and, for some artists and writers, social insurance through the artists' system. The exact result depends on status and turnover.

Employment in Germany

Income-tax bands up to 45% plus social insurance

Salary for work in Germany enters the ordinary income-tax bands. Wage-tax withholding and employee social insurance apply under their current thresholds, with employer contributions alongside.

Remote work for a foreign employer

German tax; employer payroll and business-presence risk

Work performed from Germany is normally within German employment tax. The foreign employer can acquire payroll duties or a taxable business presence. The treaty separately decides which country taxes the employment income.

Self-employment and consulting

Income-tax bands; a business can add trade tax

A qualifying liberal professional can have freelance income without trade tax. Another consultant can be a commercial business subject to municipal trade tax. Social-insurance duties depend on the profession and facts.

Director fees

Separate treaty article

Director remuneration enters personal income and has its own treaty article. The company country can retain taxing rights even when the director performs some work from Germany.

New-resident employment rule

No general expat rate

Germany has no general reduced tax rate for a newly arrived employee. Ordinary income tax, payroll, social insurance and treaty rules apply from the start of residence and German work.

Listed shares

27.5% flat (final investment withholding tax where Austrian custodian involved)

The rate line above gives the resident result. The rule is tested when the asset is sold or otherwise disposed of.

Fund and ETF units

27.5% flat

Fund/ETF unit gains carry tax at 27.5% like shares. Austria taxes by the fund's look-through income character rather than by domicile.

Losses

27.5% pooled capital-income offset

Losses on 27.5%-rate securities can be offset against gains and other positive 27.5%-rate capital income (dividends, fund income) within the same year. They cannot be set against 25% savings interest, against real-estate property-gains tax income, or against progressively taxed income.

Foreign and US listings

27.5% on the gain

A resident's gain on a foreign or US-listed share carries tax at 27.5% exactly like an Austrian share. A foreign/US-domiciled ETF is taxed on its fund character at 27.5% but is usually 'non-reporting'. Check the treaty for source tax and Austria's relief.

Accumulating funds and annual tax

27.5% annually on deemed-distributed income

Austria does not let an accumulating fund defer all income until sale. Income treated as distributed each year carries tax at 27.5%.

Austrian company dividend

27.5% final investment withholding tax

The rate line above gives the resident result. The rule is tested when the income is received.

Foreign listed-share dividend

27.5% plus tax taken abroad

The resident owes 27.5% Austrian tax on the gross foreign dividend. The source country may withhold (treaty-limited).

EU or EEA company dividend

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Third-country company dividend

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Fund or ETF distribution

27.5%

An actual fund distribution carries 27.5% tax on receipt. An accumulating fund instead pays tax through its annual deemed distribution.

New-resident treatment

No separate rule

Austria has no non-domiciled resident, remittance or general newcomer regime affecting dividends. The new resident is taxed on worldwide dividends at 27.5% from the start of residence.

Sale for money

27.5%

A sale of crypto to fiat (a 'realised increase in value') carries tax at the 27.5% special rate. Losses offset other 27.5% capital income in-year.

Crypto-to-crypto exchange

Not a disposal, tax deferred

Swapping one crypto-asset for another is explicitly not a disposal and is not taxed. The acquired asset carries the surrendered asset's acquisition cost, so the gain is deferred to the eventual sale to fiat/goods.

Spending crypto

27.5%

Exchanging crypto for goods, services or fiat (that is spending) is a realisation of the crypto taxed at 27.5% on the gain. Only crypto-for-crypto is carved out of the sale definition.

Holding relief and losses

No separate rule

For new assets (acquired from the cutoff onward) there is no holding-period relief and no annual allowance. Crypto acquired before the cutoff is treated as pre-existing holdings outside the new regime and, having passed the former one-year speculation period, is effectively exempt on sale.

Staking and lending

Different rules apply

Classical (protocol) staking rewards are not taxed on inflow. The coins are deemed acquired at zero cost, so tax (27.5%) falls only when they are later sold.

Mining, validation and airdrops

Different rules apply

For this case, mining/validation rewards are current income taxed at 27.5% at the market value on receipt (the mining coins are acquired at that value). For this case, airdrops and similar zero-consideration acquisitions are, like staking, deemed acquired at zero cost and taxed only on later disposal at 27.5%.

Private investor or business

27.5% private vs progressive (up to 55%) if core business

The rate line above gives the resident result. The rule is tested when the relevant tax event occurs.

Wealth tax and departure tax

Different rules apply

The rate line above gives the resident result. The rule is tested when the relevant tax event occurs.

New-resident treatment

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Austria pension

Progressive, up to 55%

A domestic pension is income from employment, taxed at the progressive rates with wage tax (Lohnsteuer) withheld by the paying pension body. The 13th/14th special payments (April/October) are taxed favourably like the holiday/Christmas bonus for employees.

Foreign state or social-security pension

Income-tax bands

A foreign state or social-security pension is within a resident's worldwide income and taxable in Austria as pension income unless the treaty assigns it to the source state. Austria makes no domestic reduced rate.

Foreign occupational or private pension

As progressive income, up to 55%

There is no reduced rate for being foreign, and no special foreign-pension regime. Check the treaty for source tax and Austria's relief.

Foreign government or civil-service pension

Usually source-state taxed

The specific treaty article governs. Austria typically exempts-with-progression where it is source-taxed.

Foreign pension lump sum

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Special foreign-pension rule

No separate rule

Austria has no special or reduced regime for foreign pension income.

Company profit

Taxable under the ordinary rule

An Austrian private or public company pays 23% company tax on retained or distributed profit. A loss-making company can still owe a minimum company tax, creditable against future company tax.

Distribution from an Austrian company

27.5% investment withholding tax (integrated about 44.2% with 23% company tax)

A dividend from the owner's Austrian company falls under 27.5% investment withholding tax at the individual level, final. For this case, combined with the 23% corporate layer the integrated rate on distributed profit is about 44.2% (23% plus 27.5% of the remaining 77%).

Distribution from a foreign company

27.5% plus tax taken abroad

A dividend from the owner's foreign company carries tax at 27.5%, with no participation exemption for an individual holder. Tax taken in the source country can receive treaty credit.

Foreign entity type

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Sale of your company stake

Taxable under the ordinary rule

Sale of the owner's shares (Austrian or foreign company) carries tax at 27.5% on the gain. The latent gain on the shares is caught by the exit tax at departure fair market value.

Salary or director fee

Progressive up to 55% plus social contributions

For this case, salary from the owner's company is employment income at progressive rates (up to 55%) with wage tax and social security. The owner's status changes the social-charge base.

Social contributions and remuneration risk

Self-employed social insurance vs employee social insurance employee

A managing owner's remuneration can fall within employee or self-employed social insurance, depending on shareholding and control. A shareholder above 25% is generally treated as self-employed.

Running the company from Austria

Foreign company can become Austrian-resident at 23%

A corporation is Austrian-resident and taxed on worldwide profit at 23% if its legal seat or its place of effective management is in Austria. This is a main owner-move risk.

Controlled foreign company rules

Current taxation of low-taxed (<15%) passive controlled foreign companies profits, corporate level only

The rate line above gives the resident result. The rule is tested each year.

New-resident treatment

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Review the company and your personal position together before the move.

Property in Austria

Progressive up to 55%

The rate line above gives the resident result. The rule is tested when the income is received.

Property abroad

Income-tax bands

Using the standard treaty immovable-property article the source state taxes rent from foreign property first. Austria, as residence state, usually exempts the net foreign rent but includes it to set the progression rate on the rest of the income (exemption-with-progression).

EU or EEA property branch

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Rental deductions

Income-tax bands

Rental income is taxed net. Interest, maintenance/repairs and building depreciation are deductible.

Austria main home

Exempt under the main-home rule

This case is exempt when the stated conditions are met. The holding period, asset type or treaty can change that result.

Austria investment or second property

30% property-gains tax on the gain

The rate line above gives the resident result. The rule is tested when the asset is sold or otherwise disposed of.

Foreign property

Special rule

Using the treaty immovable-property/capital-gains articles the source state taxes a gain on property situated there. For this case, Austria as residence state usually exempts the foreign-property gain but counts it for the progression rate (or credits, depending on the treaty).

Foreign EU or EEA property branch

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Foreign third-country property branch

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Main-home conditions

2-year or 5-of-10-year residence

This case is exempt when the stated conditions are met. The holding period, asset type or treaty can change that result.

Starting value after a move

Historic basis (no step-up for real estate)

Real estate does not get an entry step-up. Property-gains tax is computed from the actual (historic) acquisition cost, and for pre-2002 'old' Austrian plots a notional basis applies.

New-resident treatment

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Austria royalties

Progressive up to 55%

Royalties received by an Austrian resident are ordinary progressive income. Either income from the letting/leasing of rights (Einkuenfte aus Vermietung und Verpachtung) if passive, or self-employment/business income if the author/creator is actively exploiting the right.

Foreign royalties

Income-tax bands

Foreign royalties are within worldwide income, taxed at progressive rates, with a credit for treaty-limited tax taken in the source country. The EU Interest & Royalties Directive can cut intra-EU related-party royalty withholding tax to zero.

Which rights qualify

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Passive or active

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Social contributions and value-added tax

No safe answer yet

No safe answer is shown for this exact case yet. Check the facts and treaty before relying on a result.

Employment in Austria

Progressive up to 55% plus about 18% employee social security

Employment income carries tax at the progressive rates with wage tax withheld by the employer. Employee social-security contributions are about 18.07% up to a monthly cap (about €6,930), and the 13th/14th salary special payments are taxed favourably.

Remote work for a foreign employer

Income-tax bands

A foreign employer risks creating an Austrian permanent establishment or a wage-withholding/social-security registration obligation for a home-office employee. Check the treaty for source tax and Austria's relief.

Self-employment and consulting

Progressive up to 55% plus self-employed social insurance social contributions

Self-employment/business income carries tax at the progressive rates on net profit, plus mandatory self-employed social insurance. The 13% basic business allowance (Grundfreibetrag / Gewinnfreibetrag) applies to lower profits.

Director fees

Income-tax bands

Directors' fees are a separate treaty category: the state. This applies where the company is resident may tax a director's fee even if the work is done elsewhere.

New-resident worker rule

(scientists or researchers only)

The rate line above gives the resident result. The rule is tested when the relevant tax event occurs.