Relocation Germany & Switzerland

Moving between Germany and Switzerland is not a border crossing for tax purposes. It is a system change. In Germany, crypto gains are tax-free after one year and fully taxable before. In Switzerland, private capital gains are generally tax-free, but the cantons tax your wealth annually. Between the two systems sits the double taxation treaty with a feature that exists nowhere else in the world: the overarching taxation. Plan this switch instead of just executing it, and you save real money. Get it wrong, and you pay twice or receive mail from Germany years later.

Moving to Switzerland: the three critical points

1. The timing of your sales

Until the actual departure you are subject to unlimited German tax liability: every sale within the holding period before the move is taxed in Germany as usual. The order matters: which positions are already tax-free (older than one year), which are worth the wait, which should only be touched after the switch? This planning ideally starts six to twelve months before the move, together with the tax optimization of your existing positions.

2. The departure must be real

Unlimited tax liability continues for anyone keeping a residence or habitual abode in Germany. The popular 183-day rule of thumb does not help if the German apartment stays or the center of life effectively remains here. Tax offices examine these cases closely: leases, family home, club memberships, doctor visits. A half-hearted departure is no departure for tax purposes, and in doubt the burden of proof is yours. I make sure your move holds on paper what it is in fact.

3. The overarching taxation

Art. 4 para. 4 of the Germany-Switzerland treaty allows Germany to claim extended taxing rights against emigrants who were subject to unlimited German tax liability for at least five years, in the year of departure and the following five years. Swiss citizens are exempt. Which of your income streams are concretely affected depends on the individual case, and exactly this review belongs in every serious relocation plan towards Switzerland. If you first hear about it in a tax assessment, the planning step was skipped.

German exit taxation: who it really hits

Exit taxation under Sec. 6 of the German Foreign Tax Act covers substantial shareholdings in corporations and entrepreneurial assets, not crypto held privately. The all-clear is conditional though: anyone holding company shares alongside crypto, using a holding structure or trading commercially has the topic on the table. And the classification as a commercial trader can matter in Switzerland too, where only private capital gains are tax-free, commercial ones are not. I review both classifications before you move, not after.

Moving to Germany: holding periods and documentation

In the other direction: with the move you become subject to unlimited German tax liability, and your crypto holdings bring their history with them. Acquisition dates and holding periods continue, the move itself is not an acquisition event. Good news for long-term holders: hold your coins longer than a year and you sell tax-free as a new German resident too, under Sec. 23 EStG. The bad news: you must be able to prove it. A seamless history from your Swiss time is mandatory, best built before the move while all accounts are still accessible. How that works: Crypto Reporting & Audit.

How the advisory works

1. Scenario calculation. Stay, move, move when: you get the variants with concrete numbers, including the honest answer if the move does not pay off for you.
2. Timing plan. Sales, holding periods, moving date and deregistration are aligned, with a clear task list for you.
3. Documentation. Holdings, acquisition data and history are prepared border-proof, so both tax administrations can be served.
4. Support in the new system. For the Swiss side I cooperate with local fiduciaries where needed, the German side stays fully with me, including your final German tax return for the year of departure.

Costs

Relocation advice is custom work and depends on asset structure and complexity. After the free initial consultation you receive a fixed offer. Measured against what is at stake in a mistimed move, the planning is by far the cheapest part of the relocation.

Residence and habitual abode: what really counts

Whether you remain taxable in Germany after the move is decided not by your passport but by two concepts of the Fiscal Code. You have a residence if you keep a home under circumstances suggesting you will retain and use it (Sec. 8 Fiscal Code). You have your habitual abode where you stay not merely temporarily, as a rule more than six months continuously (Sec. 9 Fiscal Code). Even a retained apartment in Germany can keep your unlimited tax liability alive, even if you spend most of your time in Switzerland. The common 183-day rule of thumb is therefore only half the truth. I check your actual living situation before the tax office does.

The extended limited tax liability (Sec. 2 German Foreign Tax Act)

Besides the overarching taxation specific to Switzerland, there is a second relocation trap many overlook: the extended limited tax liability under Sec. 2 AStG. It applies to German citizens moving to a low-tax country who were fully taxable for at least five of the last ten years and keep substantial economic interests in Germany. The consequence: for up to ten years after the move, certain German-source income stays taxable in Germany. Whether Switzerland counts as a low-tax country in your case depends on the canton and your individual burden and must be checked individually. For Switzerland the overarching taxation usually dominates; Sec. 2 AStG is the additional layer that belongs in serious planning.

The Swiss system in detail: wealth tax and cantons

Switzerland generally does not tax private capital gains, but it levies an annual wealth tax on net assets, which include crypto. Rates and allowances differ markedly between cantons, so the place of residence directly affects the burden, and there is an annual duty to declare holdings. Anyone classified as a commercial securities trader loses the tax exemption on capital gains, so this classification matters on the Swiss side too. A lump-sum taxation by expenditure, available in some cantons, only applies under narrow conditions and without gainful employment in Switzerland, and must be checked case by case. For the Swiss side I work with local tax agents where needed; the German side stays entirely with me.

A twelve-month relocation roadmap

A tax-optimized move ideally starts about a year ahead. Roughly: first the inventory of all coins with holding periods and a check of shareholdings and business assets. Then the decision which positions to sell tax-free in Germany and which to take to Switzerland deliberately. Next the genuine change of residence with clean deregistration and documentation, plus the cross-border preparation of the crypto history. Finally the last German tax return in the year of departure and the start in the Swiss system. Following this order avoids the expensive mistakes that arise when people move first and ask later.

Avoiding double taxation: credit under the treaty

If the overarching taxation under Art. 4 para. 4 of the Germany-Switzerland tax treaty applies in the year of departure and the following five years, the same income can in principle be captured in both states. To prevent real double taxation, the treaty provides for crediting the tax paid in Switzerland against the German tax where foreseen. The credit must be claimed and evidenced, it does not happen automatically. Note that the compatibility of the overarching taxation with European law is the subject of a referral to the European Court of Justice, so the legal position may change. Exactly this interface between the two systems is where unguided moves lose money.

As of June 2026. This text is general information and does not replace individual cross-border advice.