The German exit tax, plainly
Leave Germany while holding 1% or more of a company (your GmbH or UG), and German law taxes the built-up paper gain at departure — the Wegzugsbesteuerung, cash due on value that stays unsold. Two clean sequences avoid the sting entirely: move before incorporating anything valuable and build the structure fresh on the Dutch side, or — with an existing German company already carrying value — have a German adviser price the departure first, because timing and structure change the bill dramatically. The Dutch counterpart, for symmetry: our exit mechanism defers interest free while you hold, per the exit rules.
What ends, what starts
- Ends: German unlimited tax liability once residence genuinely moves, the Sozialversicherung logic, and the trade-tax layer on the company.
- Starts: the Dutch structure — retained profit at 19%/25.8%, the holding above it, and for arrivals meeting the salary norm the expat ruling (a facility Germany barely mirrors). A multi-year lower customary salary agreed with the tax authority, combined with borrowing up to €500,000 from your own BV (besloten vennootschap, the Dutch private limited company), saves roughly €18,000 to €20,000 a year in the growth phase.
- Travels with you: the 0% US royalty rate — both treaties grant it, so the American revenue line stays whole.
The German-audience question
Creators serving a German-language audience keep serving it from Amsterdam friction-free: the market is a border away, EU rules carry the commerce, and brand deals with German advertisers invoice under the reverse charge as before. What changes is the machinery around the income, laid out city-against-city in Amsterdam versus Berlin.
The sequence
Deregister in Germany, register here (IN Amsterdam smooths it), incorporate the structure on this side, and document the management move if any German entity travels along. The standard 90 days: moving to Amsterdam.