27.11
🌍 27 · Emigrating as a Trader

📊 Focus Countries Compared

Cyprus, Portugal, Malta, Andorra, UAE, Thailand and Georgia in one comparison table: capital gains tax, minimum stay, system, EU status, tax treaty and §2 AStG risk at a glance.

In this Chapter

1 What This Is About 2 The Comparison Table 3 How to Read the Table 4 Sources

1. What This Is About

World map with glowing connection lines and location markers — symbolic image for country comparison
📊 Focus countries · Comparison All 7 compared Capital gains tax · residency · tax treaty
📅 Snapshot: July 2026 📊 Seven focus countries side by side — condensed from the individual country chapters

This page places the seven focus countries of the emigration cluster — Cyprus, Portugal, Malta, Andorra, the UAE (Dubai), Thailand and Georgia — side by side in a single table. It is meant as a quick orientation: which country taxes capital gains how, how many days you need to spend there, whether it is an EU country or a third country, and how strict the German § 2 AStG is. All figures are condensed from the respective country chapters — the detail with sources, footnotes and exceptions is found there. The table gives only the short version.

Legend for the columns:

  • EU? — ✅ = EU member (freedom of movement, euro, EU exit-tax relief); ❌ = third country.
  • Tax Treaty DE/AT/CH — whether a double taxation treaty with Germany / Austria / Switzerland is in force (✅) or not (❌).
  • § 2 AStG risk — rough classification of the extended limited tax liability: "textbook case" = clear low-tax country, review is real; "disputed/case-by-case" = classification open; "low" = generally not a low-tax country. Applies in any case only where substantial domestic interests continue to exist.
  • Entry/Substance — what the relocation actually costs or requires (investment, minimum tax, residence/activity).

⚠️ Not tax advice. The table is a condensed orientation, not a substitute for individual advice. Tax treatment depends on the specifics of each case (instruments used, trading intensity, remaining ties to Germany, Austria or Switzerland). Before emigrating, always consult an advisor specialized in both the destination country and your country of origin.

2. The Comparison Table

Country Capital Gains Tax Minimum Stay System EU? Tax Treaty DE/AT/CH § 2 AStG Risk Entry/Substance Main Catch Suited For
🇨🇾 Cyprus 0 % on "titles" (shares, bonds, options); commercial / CFD / crypto gray area up to 35 % 60 days (with conditions) or 183 days Non-dom (SDC exemption 17 of 20 years) ✅ EU (Euro) DE/AT/CH ✅ disputed / case-by-case Residence + activity; GESY 2.65 % (capped ~€4,770/year) CFDs/derivatives/crypto gray area; non-dom ends after 17 years Traders with classic securities/options and a genuine center of life
🇵🇹 Portugal 28 % flat; short-term (< 365 days) mandatorily progressive up to ~53 % at high income 183 days or residence on 31 December Standard rules (NHR closed since 1 January 2024; IFICI does not apply to traders) ✅ EU (Euro) DE/AT/CH ✅ low (28 % standard rate = generally not a low-tax country) NIF + registration; no investment hurdle no securities tax exemption; old NHR gone for new arrivals Buy-and-hold / quality of life — not for high-frequency short-term traders
🇲🇹 Malta foreign capital gains 0 % (even when remitted); commercial trading up to 35 % 183 days Non-dom remittance (no time limit) ✅ EU (Euro) DE/AT/CH ✅ delicate (non-dom as "preferential taxation") Non-dom; minimum tax €5,000/year for foreign income of €35,000 or more (creditable) remittance trap on income; badges of trade → commercial up to 35 % Investors / calmer traders with capital gains from a foreign brokerage account
🇦🇩 Andorra 0 % for a shareholding up to 25 % (savings-base allowance €3,000); top rate 10 % Active ≥ 183 days; passive ~90-day permit (for tax residency vis-à-vis Germany, Austria and Switzerland, genuinely > 183 days) Low-tax (IRPF max. 10 %) ❌ Third country (Euro by agreement) DE ❌ (under negotiation) · AT signed (May 2026, entry into force open) · CH ❌ Textbook case (clear low-tax country) Passive residency ~€1 million investment + ~€50,000 non-refundable levy high entry costs; third country wealthy investors / calmer traders with minority holdings (< 25 %)
🇦🇪 UAE (Dubai) 0 % (private portfolio); 9 % Corporate Tax for a company/license (from AED 375,000 profit / AED 1 million turnover) 183 days; or 90 days conditional; or center of life Zero tax (0 % income tax) ❌ Third country DE ❌ (lapsed since 2022) · AT ✅ · CH ✅ Textbook case (0 % = low-tax country, without DE treaty mitigation) Residence visa (property/company/Golden Visa); genuine relocation of center of life no DE tax treaty; Corporate Tax for license/company private proprietary traders with a genuine move and minority holdings
🇹🇭 Thailand 0 %, as long as not remitted; if remitted, progressive 0–35 % (LTR visa can exempt) 180 days Remittance principle ❌ Third country DE/AT/CH ✅ not categorical — concrete tax-burden comparison (effectively low through remittance/LTR) Visa (Non-Immigrant / LTR up to 10 years / Thailand Privilege) Remittance trap; legal situation in flux since 2024 Traders who leave capital in a foreign brokerage account; LTR holders
🇬🇪 Georgia foreign capital gains 0 % (no remittance condition); Georgian-source income 20 % flat 183 days; or HNWI without day counting Territorial principle ❌ Third country DE/AT/CH ✅ Textbook case (0 % = low-tax country) 183 days or HNWI (wealth > GEL 3 million or income > GEL 200,000 + Georgia connection); many nationalities visa-free for up to 365 days 1 % Small Business status does not apply to securities trading; source question private foreign-brokerage-account traders with a genuine move

3. How to Read the Table

The table condenses each country to a single row — the price for that is that nuances get lost. Three patterns help with interpretation:

  • "0 %" doesn't mean unconditional. Almost everywhere, the tax exemption applies only to privately managed securities/options trading. As soon as the activity is classified as commercial (Cyprus, Malta, Andorra, UAE, Georgia) or — as in Thailand — the gain is remitted to the destination country, the burden can rise significantly. The "Main Catch" column names the critical point in each case.
  • EU vs. third country shapes the move. The three EU destinations (Cyprus, Portugal, Malta) bring freedom of movement and a dense treaty network; the four third countries (Andorra, UAE, Thailand, Georgia) require visas/investments and in some cases have no tax treaty with Germany (Andorra, UAE).
  • The expensive part often lies in the country of origin. § 6 AStG (exit taxation for a shareholding of 1 % or more or large funds) and § 2 AStG (extended limited tax liability) are decided upon leaving Germany, Austria or Switzerland — regardless of how favorable the destination country is.

For the full picture of each country — with rates, exceptions, residency routes and the interaction with Germany, Austria and Switzerland — the seven deep-dives lead the way:

Caution — understand the departure side firstEmigration Pillar · Exit Taxation & §2 AStGThe expensive part often happens when leaving Germany, Austria or Switzerland, not upon arrival in the destination country.

4. Sources

Snapshot of all figures: July 2026. This table contains no sources of its own — each cell is condensed from the respective country chapter, where the full sources are listed (PwC Worldwide Tax Summaries, national tax authorities, BMF/RIS/ESTV on the tax treaties, gesetze-im-internet.de on § 2 and § 6 AStG). Not tax advice — obtain a professional assessment of your individual case before emigrating.

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