
Not tax or legal advice. This page sorts public sources, as of 31 Oct 2026. Whether and how any of it applies to you is a question for your tax adviser.
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:
- Exit tax: if you leave Germany holding company shares, § 6 AStG can apply. More: Exit tax and Moving from Germany to Liechtenstein.
- CFC rules: certain income of a low-taxed foreign company can be taxed in Germany at shareholder level (§§ 7 ff. AStG).
- Place of effective management: if the key decisions are made in Germany, the company can be taxable there (§ 10 AO). What real substance means: Substance in Liechtenstein.
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.
| Country | Status 31 Oct 2026 | Source |
|---|---|---|
| Germany | Law 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) |
| Italy | Proposed, 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
| Item | Status | Source |
|---|---|---|
| Corporate income tax | 12.5%, since 2011 (Tax Act in force since 1 Jan 2011) | llv.li, gesetze.li SteG |
| Minimum corporate income tax | CHF 1,800 a year | llv.li |
| EEA | Member since 1995 | gesetze.li |
| Currency | Swiss franc (CHF) | – |
| Blockchain Act (TVTG) | in force since 2020 | gesetze.li |
| GmbH (LLC) | from CHF 10,000 share capital | GmbH fact sheet, llv.li |
| EU list of non-cooperative tax jurisdictions | Liechtenstein is not on it (update 9 Oct 2026) | Council of the EU |
| AI-specific tax | none | – |
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.
Read next
Sources
- tagesschau.de: Minister Prien calls for an AI tax (29 Oct 2026, German)
- n-tv.de: Experts take apart the AI tax proposal (German)
- n-tv.de (video, 13 Oct 2026): Digital Minister Wildberger backtracks on AI tax (German)
- Assemblée nationale: amendment I-1358, PLF 2027 (adopted, 30 Oct 2026, French)
- politiquematin.fr: vote 11 to 10 against the government (French)
- Europe 1: 2027 budget, MPs vote for a per-gigabyte levy (French)
- Sénat: PLF 2027 file (French)
- Il Sole 24 Ore: exit tax in the 2027 budget bill (31 Oct 2026, Italian)
- la Repubblica: exit tax on capital gains when leaving Italy (30 Oct 2026, Italian)
- § 6 AStG (exit tax), gesetze-im-internet.de (German)
- llv.li: corporate income tax (German)
- Council of the EU: EU list of non-cooperative jurisdictions, update 9 Oct 2026
- llv.li: GmbH fact sheet (German)
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.