Streaming Income: Taxation after Moving Away from Germany

Published on 08.10.2026

Streaming Income and Moving Abroad

Anyone who earns money from livestreams, videos or social media content can work from anywhere, so the idea of moving one’s residence abroad is an obvious one. However, streaming income tax after moving abroad is considerably more complex than anecdotal reports within the creator scene suggest. Deregistering with the residents’ registration office (Einwohnermeldeamt) does not end German tax liability, the move itself can trigger a substantial tax on unrealised values, and even afterwards Germany may retain access to parts of the income. This article sets out the German rules in the order in which they become relevant in practice (legal position as at September 2026).

Why Streaming Income Is Particularly Delicate When Moving Abroad

In the view of the tax authorities, streamers, YouTubers and influencers as a rule earn business income (Einkünfte aus Gewerbebetrieb) under Section 15 of the German Income Tax Act (Einkommensteuergesetz, EStG). The Ministry of Finance of Schleswig-Holstein set this out in detail in its short information note (Kurzinformation) of 2 July 2024 (VI 3010 – S 2240 – 190); income from self-employment (selbständige Arbeit) under Section 18 EStG only comes into question if, in the individual case, an artistic or literary activity predominates. According to this guidance, benefits in kind, such as products provided free of charge, form part of operating receipts (Betriebseinnahmen) at their market value.

Two things follow from this: there are business assets that are “taken along” for tax purposes on the move, and there is a permanent establishment (Betriebsstätte) whose location determines the right to tax current profits. In addition, the income comes from very different sources:

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Step 1: Does Unlimited Tax Liability End at All?

Under Section 1 (1) EStG, anyone who has a residence (Wohnsitz) or habitual abode (gewöhnlicher Aufenthalt) in Germany has unlimited tax liability on their worldwide income. The registered address is irrelevant.

Residence (Section 8 of the German Fiscal Code, Abgabenordnung, AO): A person has a residence where they have a dwelling under circumstances indicating that they will keep and use it. A room in the parental home that remains furnished, a rented flat whose tenancy has not been terminated or an owner-occupied flat used for shoots can be sufficient.

Habitual abode (Section 9 AO): A continuous stay of more than six months is always deemed to be a habitual abode, from the very beginning; short interruptions are disregarded. The exception for stays purely for visits or recreation of up to one year does not, as a rule, fit streamers who continue to work here. The rule of thumb about “183 days” comes from double taxation treaties, where it concerns employees. The differences are explained in our article on the 183-day rule and habitual abode, and the basics in our article on habitual abode in German tax law.

There is no split in the year of the move: under Section 2 (7) sentence 3 EStG, domestic income from the period of limited tax liability is included in the assessment for unlimited tax liability. To prove the move, the termination or sale of the flat, handover reports, the foreign tenancy agreement and complete travel documentation should be kept. In cross-border matters, the taxpayer has an increased duty to cooperate under Section 90 (2) AO.

Step 2: The Move as a Discontinuation of the Business

The most expensive moment from a tax perspective is frequently the move itself. If no domestic permanent establishment remains, Germany loses the right to tax future profits from the business assets. Under Section 16 (3a) EStG, the exclusion or restriction of Germany’s right to tax the gain from the sale of all the assets of the business is treated as a discontinuation of the business (Betriebsaufgabe). For individual assets, Section 4 (1) sentences 3 and 4 EStG provides for the same as a deemed withdrawal (Entnahme), for example where an asset is allocated to a foreign permanent establishment. The same applies to income from self-employment via Section 18 (3) EStG.

The assets are valued at fair market value (gemeiner Wert), i.e. the amount an unrelated buyer would pay. The difference from the book value is taxed even though no money flows. The following may be affected:

• Equipment and studio: Cameras, computers, lighting, furniture, even if they have already been depreciated.
• Intangible assets: Channel, community and reach, trademark rights, domains, format rights, ongoing cooperation agreements.
• Self-created assets: These could not be capitalised because they were not acquired, so their book value is zero; when fair market value is applied, they are captured in full.

How an asset tied to the person of the creator is to be valued, and whether it is a transferable asset at all, is disputed and depends on the individual case. A documented valuation before the move is therefore advisable.

Example (fictitious): Streamer Timo runs his channel as a sole proprietor. The book value of the business assets is EUR 15,000; according to a valuation report, the fair market value of the equipment, trademark rights and channel is EUR 315,000. If Timo moves away without a domestic permanent establishment, a gain on discontinuation (Aufgabegewinn) of EUR 300,000 arises, which is taxed at his personal tax rate.

The allowance under Section 16 (4) EStG (EUR 45,000, only from 55 years of age or in the event of permanent incapacity to work, tapering off from a gain of EUR 136,000) and the reduced tax rate under Section 34 EStG can provide relief. According to the tax authorities’ view (R 7.1 (3) of the Trade Tax Guidelines, GewStR), the gain on discontinuation of a natural person is in principle not subject to trade tax (Gewerbesteuer).

Instalments or Compensating Item: Only for the EU/EEA

Whether the tax is due immediately depends on the destination state:

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The instalments become due early if, for example, the asset is sold or the business is discontinued or transferred to a third country (Section 36 (5) sentence 4 EStG). Because sentence 4 no. 3 also mentions ceasing to have unlimited tax liability in Germany, it must be examined in the individual case whether the instalments are preserved when the person himself or herself moves away. The continued fulfilment of the requirements must be notified annually. How the move affects freelancers in detail is covered in our article on business relocation abroad for freelancers.

Creators with Their Own GmbH

Anyone who runs their channel through a GmbH is affected differently: here, Section 6 of the German Foreign Tax Act (Außensteuergesetz, AStG) applies when the shareholder moves away. Since the 2022 reform, unlimited tax liability for a total of at least seven years within the last twelve years is sufficient; deferral is only granted on application in seven annual instalments and as a rule against security. Details are set out in our article on exit tax on GmbH shares.

Detour via an Intermediate State

In practice, some people consider moving not directly to a low-tax country but first to a country without low taxation and only after a “decent interval” to move on from there. The trap: the intermediate state may also have its own exit taxation that applies on the onward move. The intermediate stop may then create its own problems instead of merely avoiding German exit tax. For example, Austria treats the loss of its right to tax capital assets as a sale (Section 27 (6) no. 1 of the Austrian Income Tax Act, öEStG), and France taxes unrealised gains on certain shareholdings on departure (Art. 167 bis of the French General Tax Code, CGI), but there only after at least six years of residence within the last ten years. Whether and how the intermediate state taxes must therefore be examined in advance by a local adviser.

From a German perspective, too, the detour is not without consequences:

• Instalments under Section 36 (5) EStG: The outstanding tax becomes due if the taxpayer becomes resident in a state outside the EU and EEA or if the business or assets are transferred there (Section 36 (5) sentence 4 nos. 1 to 3 EStG). Moving on from an EU intermediate state to a third country therefore ends the instalment payments.
• Extended limited tax liability (erweiterte beschränkte Steuerpflicht) under Section 2 AStG: This applies until the end of ten years after the end of the year in which German unlimited tax liability ended and is linked to the person “being” resident in a low-tax territory. According to the wording, it may therefore also apply if the onward move to the low-tax country only takes place later within this period, namely for the remaining years (see below).

Unclear legal position: obtain a binding ruling. Where the tax assessment in Germany is not certain or may foreseeably change, an application for a binding ruling (verbindliche Auskunft) from the tax office (Section 89 (2) AO) should precede implementation. The ruling binds the tax office to the assessment given for a precisely defined set of facts that has not yet been implemented, and a fee is charged for it. If the tax adviser does not recommend this in such a situation, in our view he or she is acting irresponsibly: the client risks having to litigate over the outcome years later, and that costs time and money.

Step 3: What Germany Still Taxes after the Move

If unlimited tax liability ends, limited tax liability under Section 1 (4) EStG remains for domestic income within the meaning of Section 49 EStG.

Permanent Establishment or Permanent Representative in Germany

Under Section 49 (1) no. 2 (a) EStG, business income is domestic income insofar as a permanent establishment is maintained or a permanent representative (ständiger Vertreter) is appointed for it in Germany. In its circular of 18 June 2026 (IV B 2 – S 1301/01410/007/264), the Federal Ministry of Finance (BMF) issued new guidance on the permanent establishment and, for the first time, included a separate section on influencers (paras. 147 to 150). According to this:

• Anyone who earns profit income has at least a place-of-management permanent establishment (para. 148). If there is no other fixed place of business, the taxpayer’s home is as a rule this permanent establishment (para. 41, referring to the Federal Fiscal Court (BFH) judgment of 20 December 2017, I R 98/15).
• Rooms in which content is conceived, created, edited or uploaded are typically permanent establishments (para. 149).
• Locations that are used only temporarily and not regularly, for example as a backdrop, do not constitute a permanent establishment (para. 150).

If the studio remains in Germany because a team edits and uploads there, or if the key decisions continue to be made from a German home, there is much to suggest that a domestic permanent establishment continues to exist. A manager in Germany who concludes contracts on behalf of the creator can also be a permanent representative. When a workplace in one’s own home becomes a permanent establishment is shown in our article on permanent establishment through a home office abroad.

Performances in Germany

Under Section 49 (1) no. 2 (d) EStG, income from artistic, sporting, acrobatic, entertainment or similar performances carried out or exploited in Germany is domestic income, even without a permanent establishment and irrespective of who receives the income. This concerns appearances at events, tournaments, trade fairs or in shows in Germany. Whether a livestream broadcast from abroad is “exploited” in Germany because it is watched here has not been conclusively clarified; the decisive factor is likely to be who acquires the rights to the recording and where they are used.

Licensing of Rights

If a creator grants a German company rights of use in videos, images or his or her name, which the company uses in its own campaigns, this may constitute a licensing of rights. For creators carrying on a business, such income is domestic income under Section 49 (1) no. 2 (f) EStG, and otherwise under Section 49 (1) no. 6 EStG, even without a permanent establishment, if the rights are exploited in a domestic permanent establishment or other facility. The distinction from a pure advertising service depends on the contract.

Withholding Tax under Section 50a EStG

In these cases, the payer of the remuneration is often required to act. Section 50a (1) EStG obliges the payer to withhold tax on performances carried out in Germany (no. 1), their exploitation in Germany (no. 2) and on remuneration for the licensing of rights (no. 3). Under Section 50a (2) EStG, the withholding amounts to 15 percent plus solidarity surcharge. For performances, it does not apply if the income per performance does not exceed EUR 250.

In principle, the income tax is deemed to be settled by the withholding (Section 50 (2) sentence 1 EStG). Nationals of an EU or EEA state resident in that area can deduct business expenses at the withholding stage for performances and their exploitation (Section 50a (3) EStG) or apply for an assessment (Section 50 (2) sentence 2 no. 5 EStG). If Germany has no right to tax under a double taxation treaty, the withholding may only be omitted if the Federal Central Tax Office (Bundeszentralamt für Steuern) has issued an exemption certificate (Freistellungsbescheinigung, Section 50c EStG); otherwise, only a later refund remains.

By way of distinction: on 3 April 2019, the BMF clarified that payments by German advertisers to foreign platform operators for online advertising are not subject to withholding under Section 50a (1) no. 3 EStG. This concerns the relationship between advertiser and platform, not the remuneration that a creator receives directly from sponsors.

Double Taxation Treaties: Art. 7, Art. 12 and Art. 17

Whether Germany may actually tax the income that is taxable under Section 49 EStG is decided by the applicable treaty. In simplified terms, the following applies under the OECD Model Tax Convention:

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Art. 17 overrides Art. 7: income from an appearance in Germany can be taxed here even without a permanent establishment. Whether a streamer counts as an artiste or entertainer within the meaning of the treaty depends on the nature of the performance. If there is no treaty, German law applies. How the treaties are structured is explained in our article on the basics of double taxation treaties for emigrants; for refund and exemption applications, a certificate of tax residence from the new state of residence is regularly required.

The tie-breaker rule in Art. 4 of the OECD Model must be observed: if a creator keeps a flat in Germany in addition to the new residence, the centre of vital interests decides which state is regarded as the state of residence.

Extended Limited Tax Liability under Section 2 AStG

If a German national moves to a low-tax territory, Section 2 AStG can extend Germany’s reach for up to ten years after the end of the year of the move. The requirements must be met cumulatively:

1. In the last ten years before the end of unlimited tax liability, the person, as a German, had unlimited income tax liability for a total of at least five years.
2. The person is resident in a foreign territory in which his or her income is subject only to low taxation (Section 2 (2) AStG), or is not resident in any foreign territory.
3. The person has substantial economic interests in Germany (Section 2 (3) AStG).

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Extended tax liability only applies in years in which the income subject to limited tax liability on this basis exceeds EUR 16,500. It then covers all income that would not be foreign income in the case of unlimited tax liability, i.e. considerably more than Section 49 EStG. Income earned through a foreign company can be attributed under Section 5 AStG. Anyone who first moves to a normally taxing country and only later moves on to a low-tax country may, according to the wording, be caught for the remaining years of the ten-year period if the other requirements are met. Whether a destination country has low taxation is determined by a tax burden comparison for the specific person; the foreign tax burden should be confirmed by a local adviser.

VAT after the Move

The move also changes the place of supply for VAT purposes.

• Services to businesses (platforms, sponsors, agencies) are, under Section 3a (2) of the German VAT Act (Umsatzsteuergesetz, UStG), supplied where the recipient is established. If the recipient is a German business and the creator is established abroad (Section 13b (7) UStG), the recipient as a rule owes the tax under the reverse charge procedure (Section 13b (1) UStG if established in another EU state, otherwise Section 13b (2) no. 1 UStG, in each case in conjunction with Section 13b (5) UStG); the invoice must refer to this.
• Electronic services to consumers (digital content, memberships via own websites) are supplied at the customer’s place of residence under Section 3a (5) UStG. For customers in the EU, the One-Stop Shop is available: if established in a third country, the non-EU scheme (in Germany Section 18i UStG); if established in another EU state, the procedure of the new state of establishment; a local adviser should be consulted on this.
• Payments via platforms: Whether the platform or the creator makes the supply to viewers depends on the platform’s terms and must be examined for each income channel.

VAT in the new state of residence is governed by its law; a local adviser should be consulted on this. In Germany, outstanding advance returns and the final annual return must still be filed.

Formalities: Trade Registration, Tax Office, Social Security

• Deregistration of the business: The discontinuation must be notified under Section 14 (1) of the German Trade Regulation Act (Gewerbeordnung, GewO); however, the tax consequences depend on whether a permanent establishment remains.
• Tax office: Notify the move and the discontinuation of the business, determine the gain on discontinuation, file applications under Section 36 (5) or Section 4g EStG and have advance payments adjusted.
• Contracts: Adjust sponsorship and agency agreements as well as invoice details and apply for exemption certificates if necessary.
• Social security: It follows its own rules; guidance is given in our article on social insurance obligations for digital nomads.

Typical Mistakes in Practice

Foreign company managed from Germany. A company founded abroad whose business is in fact still managed from Germany may have its place of management here and thus have unlimited liability to corporation tax. What matters here is shown in our article on moving a company’s registered office abroad.

The assumption that the tax office will not find out. Cross-check notifications (Kontrollmitteilungen) from tax audits of German clients, the automatic exchange of financial account information and reports from platform operators under the German Platform Tax Transparency Act (Plattformen-Steuertransparenzgesetz) provide leads, often only years later; corrections are then made retroactively with interest.

Conclusion

When it comes to the taxation of streaming income after moving abroad, three questions must be kept apart: whether unlimited tax liability actually ends, what tax the move itself triggers on the business assets, and which current income Germany can still reach afterwards. According to the BMF circular of 18 June 2026, rooms in which content is produced and uploaded are typically permanent establishments. Conversely, a complete move away can trigger a high tax on self-created assets, which can only be spread over five years if the destination state is in the EU or the EEA.

Frequently Asked Questions

Is deregistering with the residents’ registration office enough to stop paying taxes in Germany?

Not on its own. What matters are residence (Section 8 AO) and habitual abode (Section 9 AO), not the registered address.

Do I have to pay tax on my channel when I move away, even though I am not selling it?

That is possible. If Germany loses the right to tax the business assets, this is treated as a discontinuation of the business under Section 16 (3a) EStG; the difference between fair market value and book value is taxed.

Can I pay the tax on the gain on discontinuation in instalments?

Only if the assets are allocated to business assets in an EU or EEA state: then, on application, in five annual instalments under Section 36 (5) EStG. Whether the instalments are preserved when the person himself or herself moves away must be examined in the individual case because of Section 36 (5) sentence 4 no. 3 EStG. The law does not provide for instalments for third countries.

How are appearances in Germany taxed after the move?

They are subject to limited tax liability under Section 49 (1) no. 2 (d) EStG, with withholding tax under Section 50a EStG; Art. 17 of the OECD Model as a rule permits taxation.

Do I also need a tax adviser in the destination country?

As a rule, yes. How the new state of residence taxes income and turnover is determined by its law; a local adviser should be consulted on this.

Attorney Dr. Johannes Fiala and the Munich-based firm, which focuses on international succession law, tax law and asset protection, advise clients on the tax consequences of moving abroad, from the end of unlimited tax liability and the exit taxation of business assets to coordination with the double taxation treaty and the adviser in the destination state. Dr. Fiala has published extensively on questions of emigration and asset protection. Please get in touch with the firm without obligation to discuss your individual situation in an initial consultation.