Tax trap German shares - relocation to Montenegro with German securities account structure and review of Section 2 AStG

Tax trap German shares: check § 2 AStG when moving to Montenegro

Anyone moving from Germany to Montenegro and retaining German shares, dividends, real estate, shareholdings or other German benefits should not only plan the move from an organizational perspective. The decisive factor is whether there are still tax links in Germany after the move and whether Section 2 AStG needs to be examined professionally.

  • Objective: to make German tax ties visible before moving away.
  • Audit trail: Relocation → Residency → Germany-related matters → Deposit and asset structure → Tax consultant audit.
  • Benefit: no premature assumption that deregistration, foreign custody account or Montenegro residence alone is sufficient.

Why German equities can be a warning signal when moving away

German shares are not automatically a tax problem. However, they show that moving away for tax purposes should not be viewed solely in terms of residence, deregistration and new address. Anyone who continues to hold German income, assets or investments needs an orderly audit before moving.

The key question is not: "Where is my securities account?" But rather: What economic interests still exist in Germany after the departure, what income does this generate and how is the tax residency in Montenegro actually documented?

  • Deregistration of residence: This does not automatically end all tax links with Germany.
  • Securities account structure: German shares, dividends and planned sales must be recorded separately.
  • Germany-related: Real estate, investments, pensions, rents and commercial interests belong in the same overview.
  • Montenegro setup: Residence, living situation, center of life and local structure must match the actual relocation.

This content is not tax advice. ekosphere structures the preliminary review, organizes documents and coordinates local Montenegro steps. The tax assessment is carried out by qualified tax consultants or specialist lawyers.

Briefly describe the initial situation

What actually needs to be checked under Section 2 AStG

§ Section 2 AStG relates to extended limited tax liability and requires an overall assessment. This includes, among other things, previous tax liability in Germany, nationality, residency after departure, possible low taxation and significant economic interests in Germany.

Person and departure

  • Nationality and previous tax liability in Germany
  • Date of giving up residence and actual departure
  • Residence and center of life after the move
  • Documentation of the relocation to Montenegro

References to Germany

  • German shares, dividends and planned sales
  • German real estate, rents, bonds and investments
  • commercial or corporate interests in Germany
  • Ratio of German values to total assets and total income

The legal bases are § 2 AStG and § 49 EStG. ekosphere deliberately does not link to these sources here as a self-service route, but uses them as a basis for checking the structured preparation of the tax consultant meeting.

Why the broker location does not decide

A foreign broker can make sense from an organizational point of view. However, it does not automatically answer the tax question. The issuer, type of income, disposals, residency, domestic assets and the entire structure after the departure are important for the audit.

Enter depots

Banks, brokers, custody locations and accounts are documented. The location is recorded, but not evaluated in isolation.

Separate positions

German shares, foreign shares, funds, investments, dividends and sales are separated. Only then does the tax audit become concrete.

Prepare exam

Deposit overviews, income, acquisition values, planned sales and other German references are prepared in such a way that a tax advisor can carry out a targeted review.

Clarify securities account structure

Montenegro, DTA and tax residency

Montenegro must not be treated as a country without a double taxation agreement for tax purposes. The Federal Ministry of Finance lists Montenegro in the country-related information and documents the continued validity of the German-Yugoslavian double taxation agreement in relation to Montenegro.

However, this does not automatically solve the individual case. DTA issues, actual residency, German source of income and a possible application of Section 2 AStG must be examined together. Errors arise above all when tax planning, residence status and actual lifestyle diverge.

  • Residency: Residence situation, stay, center of life and proof must match.
  • DTA question: The agreement is relevant, but does not replace an examination of the specific tax case.
  • Residual commitment: Shares, real estate, bonds, rents and investments belong in a complete overview.
  • Specialist examination: The final tax assessment belongs to the tax consultant or specialist lawyer.

If you are preparing to move away for tax purposes, you should not deal with tax issues, residence, housing situation and supporting documents separately.

Process of the preliminary audit: from the exit plan to the tax basis

A meaningful audit does not start with conjecture, but with complete information. ekosphere collects and organizes the facts in such a way that tax consultants, specialist lawyers or banks do not have to reconstruct a case from scattered individual pieces of information.

Phase 1 - Record departure and Montenegro setup

Planned departure, residence status, stay in Montenegro, housing situation, local structure and continuing ties to Germany are examined.

Result: clear case outline instead of scattered individual details.

Phase 2 - Organize assets and income

German shares, dividends, sales, real estate, rents, pensions, investments and other income are recorded separately.

Result: Overview of tax-relevant Germany-related income.

Phase 3 - Preparing for the examination

The documents are prepared in such a way that Section 2 AStG, DTA issues, residency and possible structuring steps can be professionally examined.

Result: verifiable basis for decision, tax consultant discussion and implementation.

For whom the preliminary assessment makes sense - and for whom not

The preliminary check is intended for people who are seriously preparing their move to Montenegro and do not want to overlook any connections to Germany. It does not replace tax advice, but makes it better prepared and more targeted.

Suitable for

  • Persons planning to move to Montenegro
  • Clients with German shares, investments, real estate or current German income
  • Entrepreneurs, shareholders and investors with a connection to Germany
  • People who want to prepare documents properly for tax consultants or specialist lawyers
  • Cases in which residence, domicile, custody account, bank and local structure must be considered together

Not suitable for

  • Requests for binding tax advice without a tax consultancy mandate
  • Blanket statements such as "deregistration is enough" or "Montenegro is automatically tax-free"
  • Cases without transparent information on assets, income and portfolio structure
  • Tax savings models without actual residency and documented implementation

ekosphere accompanies structure, documentation, local Montenegro steps and coordination. Legal or tax advice is not part of this service.

Depending on the initial situation, taxes in Montenegro and a residence permit in Montenegro may also be part of the same preparation.

Classify projects

Formats & price range

Selection according to audit requirements, complexity and status of departure - from structured entry to coordinated preparation for tax advisor, bank, residence and local implementation in Montenegro.

Strategic initial meeting

Video call

150,00 €

  • 60 minutes
  • 1 - 3 participants
  • DE / EN / MNE
  • Move away, Montenegro target image and German references
  • Determine next audit trail
Book an initial consultation

Document & risk precheck

Remote Screening

450,00 €

  • Document list and upload check
  • Structuring of securities accounts, German shares and domestic income
  • List of questions for tax consultants and specialist lawyers
  • Classification of recognizable red flags
  • Check logic for the next step
Book Precheck

Operational on-site day

Structured implementation in Ulcinj

999,00 €

  • 1 day structured implementation
  • 1 - 3 participants
  • Comparison of housing situation, residence, bank and local structure
  • Preparation of relevant documents and responsibilities
  • Documented decision status
Plan an on-site day

Multi-day program

Extended relocation coordination

On request

  • Duration according to complexity
  • Relocation, residence, company, real estate and bank can be combined
  • Coordination with tax advisors and local authorities
  • Prioritization of risks, documents and follow-up steps
  • Structure for decision-making and implementation
Request program

Net prices plus 21% VAT. Tax advice is not included and is only provided by qualified professionals.

FAQ: Tax trap German shares and Montenegro

This FAQ provides answers to typical questions before moving to Montenegro. It does not replace an individual tax assessment.

Does § 2 AStG automatically apply when moving to Montenegro?

No. § Section 2 AStG does not automatically apply to every departure. Decisive factors include previous tax liability, nationality, residency after departure, possible low taxation and economic interests in Germany.

Why can German equities still be relevant?

German shares can be an indication of continued ties to Germany. However, it is not just the individual share that is decisive, but the entire asset and income structure after the move.

Is a foreign custody account sufficient?

No. A foreign securities account does not automatically answer the tax question. The issuer, type of income, dividends, sales and other German references must be checked separately.

Is Montenegro to be treated as a country without a DTA for tax purposes?

No. Montenegro must be examined separately. The Federal Ministry of Finance lists Montenegro under the state-related DTA information and documents the continued validity of the German-Yugoslav DTA in relation to Montenegro.

Which documents are important for the preliminary review?

Important are portfolio overviews, lists of German shares, dividends, sales, real estate, rental income, pensions, investments as well as information on the planned stay and living situation in Montenegro.

Which official sources are relevant?

The legal text of Section 2 AStG, Section 49 EStG on domestic income and the BMF information on Montenegro and the double taxation agreement are particularly relevant. These sources do not replace a professional assessment.

Does ekosphere provide tax advice?

No. ekosphere does not provide tax advice. We organize the case, prepare documents, structure local Montenegro steps and coordinate with qualified tax advisors if necessary.

When should the test start?

The review should begin before the actual departure. Subsequent corrections are often more difficult because residence, deposit structure, sales and documentation may have already been established by then.

Contact & Office in Ulcinj

ekosphere doo
Bulevar Teuta bb
85360 Ulcinj, Montenegro

PIB: 0317 1868
REG: 5081 9609
PDV: 82 / 31-02022-6

For initial contact, appointment requests or queries about German shares, Germany-related matters and moving to Montenegro, it makes sense to contact us directly by phone, WhatsApp or email.

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Zuletzt bearbeitet am 10.06.2026 · Autor: Semantic Sovereignty