Will Germany keep taxing me for ten years after I move to Cyprus?
Short answer
It can. Under the extended limited tax liability rules (§2 AStG), a German citizen who moves to a low-tax country while keeping substantial economic interests in Germany is taxed more widely there for the year of the move and the ten years after, in each year that income exceeds €16,500.
It applies to German citizens who were fully taxable in Germany for at least five of the ten years before leaving. Low taxation means either that tax in the new country on an income of €77,000 is more than a third below German tax, or that a preferential regime there can considerably reduce the tax. You escape it by showing that your total tax is at least two-thirds of the German tax.
Substantial economic interests include owning or co-owning a German business, holding at least 1% of a German company, or German income or assets above 30% of your total (or above €62,000 of income or €154,000 of assets).
Whether a Cyprus non-dom position counts as a preferential regime under this rule is a question for a German tax adviser. The statute sets the test, not the answer.
Sources
- Außensteuergesetz, §2: erweiterte beschränkte Steuerpflicht (gesetze-im-internet.de) gesetze-im-internet.de
Information, not advice. This answer describes the published rules as they stand on 12 October 2026, checked against the sources listed. Tax and residence rules depend on your own circumstances and change; check your position with a tax adviser qualified in Germany and in Cyprus before you act on it.
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