Europe · Western Europe

Germany

Europe's largest economy now offers dual citizenship and naturalisation in five years. But it also runs one of the continent's most aggressive exit taxes, extended in 2025 to reach ordinary investment fund holdings. The door in is wider than the door out.

Last verified July 2026190 visa-free destinations

Frequently asked

Can I now get German citizenship in five years and keep my current passport?

Yes, the 2024 reform stands. Naturalisation now generally requires five years of lawful habitual residence instead of eight. Dual citizenship has been permitted since 27 June 2024, so you no longer have to renounce your existing nationality. Your other country may still take a different view, so check that separately. You will need B1 German, the naturalisation test (Einbuergerungstest), and proof that you can support yourself without social assistance. This shift took Germany from one of Europe's most restrictive citizenship regimes to one of its more accessible ones. But the tax cost of qualifying is real. Five years of German residence means five years of worldwide taxation at up to 47.475%, with no expat regime to soften it.

Is the three-year fast-track to German citizenship still available?

No. The three-year fast-track naturalisation route, introduced alongside the 2024 reform for cases of exceptional integration, was repealed with effect from 30 October 2025. The Bundestag voted 450 to 134, and a uniform five-year minimum now applies. Anyone who had built a plan around reaching C1 German and volunteering, aiming for a passport in three years, lost that option within eighteen months. Any advice or marketing still pointing to the three-year route is out of date as of 2026.

Could my ordinary investment portfolio trigger German exit tax?

Since 1 January 2025, yes. This is the change almost nobody has priced in yet. The Annual Tax Act 2025 extended exit taxation (Wegzugsbesteuerung) to units in investment funds and ETFs through new provisions in the InvStG. That means a purely passive investor holding EUR 500,000 or more in acquisition cost in a single fund is now caught by the same deemed-disposal rule that previously applied only to shareholdings of 1%-plus in a company under section 6 AStG. On departure, unrealised gains are taxed as though you sold everything the day before you left. It is a charge on money you never received, with no cash on hand to pay it. This used to be a founder's problem. Now a large, conventionally diversified portfolio can trigger it with no operating business anywhere in sight.

How long do I have to live in Germany before the exit tax can apply?

The exit tax applies once you have been subject to unlimited German tax liability for at least 7 of the previous 12 years. That is a short window, one a family can cross during a single school cycle after arriving in Germany. The trigger is what the law calls an exit event: emigration, the loss of German taxing rights, or a gift or inheritance of the shares to a relative living abroad. That last point matters for succession planning. Moving assets to a child who lives overseas can trigger the tax even if nobody physically moves. Interest-free indefinite deferral for moves within the EU/EEA was abolished for exits from 2022 onward. The current regime offers instalment payment over seven years, generally against security. Model the exit before you plan the entry.

Does Germany have a wealth tax or any non-dom/expat regime?

No on both counts. The wealth tax has gone unenforced since the Federal Constitutional Court struck down its valuation basis in 1995, and collection stopped in 1997. It resurfaces in every election cycle, but it has never been reinstated. Germany also operates no non-dom, expat or inpatriate tax regime of any kind. You pay the full top rate of 45% plus the 5.5% solidarity surcharge, for an effective 47.475%. Add church tax of 8-9% if you are registered to a religious community, and the exit tax on the way out. There is no offsetting relief for inbound wealth.

What's the fastest route to German permanent residence?

The EU Blue Card, which grants permanent residence (Niederlassungserlaubnis) in 21 months with B1 German, or 27 months with A1, exceptional by European standards. It also exempts the spouse from the German language requirement that burdens other family-reunification routes. It requires a recognised university degree (or, for IT specialists, three years of relevant experience gained in the last seven) and a qualifying salary; for 2026, EUR 50,700 gross, or EUR 45,934.20 for shortage occupations and recent graduates. Because it is tied to the employment, losing the job jeopardises both the permit and the permanent-residence clock, and it does nothing for a family living on investment income rather than salary.

Can I move to Germany as a self-employed person or freelancer without a job offer?

Yes, through the section 21 AufenthG self-employment permit. The underused sub-route is section 21(5), for the liberal professions (Freiberufler): consultants, engineers, IT professionals, doctors, architects, writers. It carries no formal business plan requirement, no local-economic-benefit test and no requirement to have German clients. That makes it one of the most accessible self-sponsored routes into a top-tier EU economy. The commercial sub-route, section 21(1), is harder. It requires a viable business plan and a Chamber of Commerce opinion that effectively decides the case, and outcomes vary materially by city. One note worth planning around: permanent residence normally needs 60 months of statutory pension contributions, and self-employed applicants usually lack these. Plan for voluntary contributions from year one.

Does Germany have a golden visa or investor route?

No. There is no investment-for-residence programme; the closest thing is the section 21 self-employment permit, which assesses substance rather than a fixed sum, since the old EUR 250,000 threshold was removed years ago and the authorities want a genuine business rather than parked capital. Inheritance tax, meanwhile, runs from 7% to 50% by relationship class, with spouses and children in Class I with allowances of EUR 500,000 and EUR 400,000, applies to worldwide assets for German residents, and carries a 5-year tail following departing German nationals. For a wealthy family the door into Germany is wide, but the door out, via the exit tax and the inheritance-tax tail, is not.

Tax position

Income tax (top)
45% top rate, known as the Reichensteuer, above roughly EUR 278,000, plus the 5.5% solidarity surcharge on the tax itself, for an effective 47.475%. Add church tax of 8–9% of the tax if you are registered to a religious community.
Capital gains
25% Abgeltungsteuer plus solidarity surcharge, for an effective 26.375%, on portfolio income and gains. Shareholdings of 1% or more fall under §17 EStG and are taxed under the partial-income method at progressive rates. Real estate gains are exempt after a 10-year holding period, or 3 years if owner-occupied.
Wealth tax
None. The wealth tax has gone unenforced since the Federal Constitutional Court struck down its valuation basis in 1995, and collection stopped in 1997. It resurfaces in every election cycle, but it has not been reinstated.
Inheritance tax
7–50%, depending on the relationship between the parties. Spouses and children fall in Class I at 7–30%, with allowances of EUR 500,000 and EUR 400,000 respectively. Unrelated beneficiaries face Class III at 30–50%. Worldwide assets are in scope for German residents, and a 5-year tail follows departing German nationals.
Special regime
None. Germany has no expat, non-dom or inpatriate tax regime of any kind.
Territorial
No, worldwide income taxed
CFC rules
Yes
Exit tax
Yes, leaving has a cost
CRS
Participating

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