Taking your German company to Dubai. The order decides the tax bill.
Exit tax (Wegzugsbesteuerung, § 6 AStG), permanent establishment and substance can be shaped beforehand and only explained afterwards. We set the order, licensed partners review the tax, our team on the ground delivers.
As of 10/2026. Sources: § 6 AStG, UAE Federal Tax Authority, Ministerial Decision 265/2023. Not legal or tax advice; tax questions are reviewed by licensed partners.
The 4 risks to settle before the flight
Each of these risks has a point after which it only gets more expensive. That point is the move.
Exit tax (Wegzugsbesteuerung, § 6 AStG)
German law treats the move as a sale of the shares. Valuation, deferral, instalments and the return rule belong on the tax adviser’s desk before the move, not after.
Permanent establishment in Germany
If management stays in Germany in substance, the tax stays there too. Sitting in Dubai and running the GmbH from there moves the place of management. Both have consequences, and both can be planned.
Residence and habitual abode
A home in Germany that remains available at any time keeps unlimited tax liability alive. 183 days of absence on their own end nothing.
Substance in the UAE
0 % on qualifying income is earned with staff, premises, decisions and spending on the ground. A letterbox does not meet that.
Exit tax before you move · The 183-day misunderstanding · Substance, not a letterbox
3 models we see regularly.
| Model | For whom | What is set up in the UAE | Where it fails |
|---|---|---|---|
| Operating free zone company, the GmbH stays | Consulting, services, digital business models; the GmbH keeps running or is wound up | Licence, visas, bank account, substance | Management of the GmbH stays in Germany in substance |
| UAE holding above the GmbH | Holding shareholdings, receiving dividends tax-free | A holding (e.g. RAK ICC, free zone holding) plus an operating licence for visas | Exit tax unresolved, the holding lacking substance |
| Foundation (DIFC / ADGM) plus holding | Succession, family office, wealth across generations | A foundation owning the holding | Built too early, before residence and the move are settled |
What we advise against is in the written recommendation. With reasons.
How a mandate runs, in 6 steps.
First call, 15 minutes
Shareholdings, profit, family, timeline, what is still open in Germany.
Tax pre-review with the partner firm
Exit tax, permanent establishment, treaty questions. The result is a list of what to do before the move.
Written structure recommendation
Emirate, jurisdiction, licence type, visa plan, substance requirements, cost range, timeline. Plus what we advise against.
Delivery by the local team
Licence, establishment card, visas, Emirates ID, bank account. Milestones, status at any time.
Building substance
Office, staff, bookkeeping, tax registration, corporate tax filing. Documented for the review that comes later.
Ongoing support
Renewals, insurance, changes, annual accounts through partners. One point of contact.
Why Exit Palm
Partners, not a solo run
Tax and law are reviewed by licensed firms in Germany and the UAE. We coordinate them; we do not replace them.
One price, no additions
What the quote says holds, even if a step takes longer.
All 7 emirates
We recommend the jurisdiction that fits the structure, not the one with the highest commission.
Choose a time.
15 minutes, by video. Bring the shareholding structure and the planned timeline.
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Common questions
Do I have to sell or liquidate the GmbH?
No. It often stays in place, with management adjusted. Whether that makes sense depends on profit, substance and exit tax.
Is there a double taxation treaty between Germany and the UAE?
We settle this question in the first call with your case in view; the legal position is reviewed by the partner firm.
How far in advance do I have to start?
6 to 12 months before the planned move. The tax planning takes longer than the licence.
Can my family come along?
Yes, on family visas, as soon as you hold your Emirates ID as the sponsor. Details on the family page.
What does a holding structure cost?
The cost range for licence, visas and bank account comes out of the first estimate. Tax and legal advice are billed separately by the partners.
What belongs before the move in your case?
Afterwards you know the order and what you need the tax firm for.
Exit Palm does not provide legal or tax advice. For legal and tax questions we work with licensed partners in Germany and the UAE. All information without warranty; see the date for the version it reflects.
As of 10/2026