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KNOWLEDGE & GUIDES

AI tax & data levy: what's actually law?

Germany is debating an AI tax, France adopted a €0.055 per gigabyte levy at first reading. What applies, why moving doesn't get you out of them, and why Liechtenstein is a location, not an escape. As of 31 Oct 2026.

Status check 31 Oct 2026: AI tax debated in Germany, data levy at first reading in France, Liechtenstein at 12.5% corporate income tax since 2011

In short

  • In Germany, an AI tax is a demand, not a law: there is no draft and no rate.
  • In France, the Assemblée nationale adopted a levy of €0.055 per gigabyte at first reading. The Senate and the final budget are still pending.
  • Both ideas target market activity in Germany or France. Moving doesn't get you out of them, and a mailbox company certainly doesn't.
  • Germany already has an exit tax (§ 6 AStG), and Italy is planning one. If you're considering a move, plan early and with real substance.
  • Liechtenstein is still worth a look: not as an escape, but as a predictable location. With a real desk at the hub in Schaan.

Status check 31 Oct 2026

What is law, and what is only being demanded?

Sorted, with sources. None of it is law today.

DEproposed

AI tax

  • Family Minister Karin Prien told Stern that AI-driven value creation has to be taxed: “there's no other way” (tagesschau.de, 29 Oct).
  • Digital Minister Karsten Wildberger, Economy Minister Katherina Reiche and Chancellor Friedrich Merz are sceptical. Wildberger: “I want growth through AI and I'm not talking about new taxes” (n-tv.de, German).
  • No draft bill, no rate, no tax base.

FRfirst reading

Per-GB data levy

  • Amendment I-1358 to the 2027 budget bill (PLF): adopted at first reading in the Assemblée nationale on 30 Oct (assemblee-nationale.fr).
  • €0.055 per gigabyte sent to French users, including by providers without a French company.
  • Capped at 15% of French revenue or 2% of global revenue.
  • The Senate and the final budget are still open (senat.fr).

LIunchanged

Liechtenstein

  • 12.5% corporate income tax since 2011, minimum tax CHF 1,800 (llv.li).
  • No AI-specific tax.
  • Not on the EU list of non-cooperative tax jurisdictions (Council of the EU, 9 Oct 2026).

As of 31 Oct 2026. We update this page when things change.

Not an escape, a location

Plenty of posts are saying “time to move” right now. The honest part is usually missing: both ideas hinge on market activity. The French levy follows the data sent to users in France, wherever the provider is based. A German AI tax, as currently discussed, would target value created in Germany. Moving doesn't get you out of either.

A mailbox company doesn't help either. Three things decide, not the address on your letterhead:

Why we still like talking about Liechtenstein: the environment is predictable. Founders plan in years, not in headline cycles.

Exit taxes in Europe

Beyond the AI tax and the data levy, there is an older rule that people moving often underestimate: the exit tax. It taxes gains built up in the old country, even if nothing has been sold.

CountryStatus 31 Oct 2026Source
GermanyLaw in force. If you were fully taxable in Germany for at least 7 of the last 12 years and hold at least 1% of a corporation, moving away triggers tax on the gain in those shares as if you had sold them. On application, the tax can be paid in instalments over seven years.§ 6 AStG (German)
ItalyProposed, not law. The government's 2027 budget bill plans 26% on unrealised gains from shares, holdings and other financial instruments where financial assets are at least €800,000 (bank deposits excluded) and the person was tax resident in Italy for at least 6 of the last 10 years. Parliament is still debating the bill.Il Sole 24 Ore, 31 Oct 2026, la Repubblica, 30 Oct 2026 (Italian)

The logic: exit taxes mostly hit those who move late. The longer shares grow in the old country, the larger the amount that can fall due when you leave. If you are seriously considering Liechtenstein as a location, plan early, get tax advice, and build real substance: a registered company with its seat and desks on the ground, for example at the hub in Schaan, not a mailbox address. More: Exit tax, the Italy status check and every country in Tax news Europe.

Liechtenstein in numbers

ItemStatusSource
Corporate income tax12.5%, since 2011 (Tax Act in force since 1 Jan 2011)llv.li, gesetze.li SteG
Minimum corporate income taxCHF 1,800 a yearllv.li
EEAMember since 1995gesetze.li
CurrencySwiss franc (CHF)–
Blockchain Act (TVTG)in force since 2020gesetze.li
GmbH (LLC)from CHF 10,000 share capitalGmbH fact sheet, llv.li
EU list of non-cooperative tax jurisdictionsLiechtenstein is not on it (update 9 Oct 2026)Council of the EU
AI-specific taxnone–

It's not a hack. It's boringly predictable, and that's the point. How incorporation works: GmbH formation in Liechtenstein.

digihub · In der Specki 3, Schaan

Substance means a real place to work

If you're looking at Liechtenstein seriously, you need more than an address: an office, people on the ground, decisions made here. At digihub in Schaan you get real desks, not a mailbox: coworking with a Flex Desk from CHF 169, a Full Desk from CHF 299 or a Private Office from CHF 549 a month, plus meeting room and community. A business address is available by agreement (Registered office & business address).

Come by for a coffee, and we'll see together whether Liechtenstein even makes sense for you.

Not tax or legal advice. Orientation based on public sources, as of 31 Oct 2026. Legislation in Germany and France can change quickly. Please check your own case with a tax adviser or lawyer.

Content from digihub.li · reviewed 31 October 2026.

FREQUENTLY ASKED QUESTIONS

Questions and answers.

Is there already an AI tax in Germany?

No. As of 31 Oct 2026, Family Minister Karin Prien is calling for AI-driven value creation to be taxed. Digital Minister Wildberger, Economy Minister Reiche and Chancellor Merz are sceptical. There is no draft bill, no rate and no tax base.

Is France's €0.055 per gigabyte levy already law?

No. The Assemblée nationale adopted amendment I-1358 to the 2027 budget bill at first reading on 30 Oct 2026. The Senate and the final budget are still pending. The levy would be capped at 15% of French revenue or 2% of global revenue.

Can I avoid these levies by moving my company to Liechtenstein?

No. Both ideas target market activity in Germany or France. According to the amendment, the French levy would also cover providers without a French company. Moving is therefore not a way around them.

Is an address in Liechtenstein enough?

No. A mailbox company doesn't help. Exit tax (§ 6 AStG), CFC rules and the place of effective management decide. If you look at Liechtenstein seriously, you need real substance: an office, people on the ground and decisions made here. More: Substance in Liechtenstein.

Is Italy planning an exit tax?

Yes, as a proposal. The Italian government's 2027 budget bill plans 26% on unrealised gains from financial instruments, from €800,000 in financial assets and for people tax resident in at least 6 of the last 10 years. Parliament is still debating it; it is not law. Germany already has an exit tax on company shares (§ 6 AStG).

How can I get to know digihub in Schaan?

Come by for a coffee at In der Specki 3 in Schaan, or try the hub with a Day Pass. Write to us via the contact form and we'll set a time.

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