Moving from Germany to Vanuatu in 2026 is the single sharpest tax-rate cut available to a German taxpayer: the 47.5% top bracket, 26.375% Abgeltungsteuer, 7–50% Erbschaftsteuer and ~30% combined corporate rate are all replaced with a flat zero — no income tax statute exists in Vanuatu at all, no capital gains tax, no inheritance, gift or wealth tax. Vanuatu’s Development Support Program also delivers a second passport in 30–60 days, faster than any other Citizenship by Investment programme on earth. The economic case is unmatched. The execution case is the hardest in the entire German exit corridor. Vanuatu is non-EU/EEA, so §6 AStG Wegzugsteuer on substantial shareholdings runs without ATAD instalment relief and almost always pulls a Sicherheitsleistung. There is no double tax treaty and no Tax Information Exchange Agreement between Germany and Vanuatu — none has ever been signed — which removes the Article 4 tie-breaker and exposes German-source flows to full domestic withholding. Vanuatu’s 0% regime makes it a textbook Niedrigsteuerland under §2 AStG for the 10-year tail. And Vanuatu has appeared on the EU list of non-cooperative jurisdictions for tax purposes in recent years, which activates the enhanced cooperation duties under §162 Abs. 4 AO and the Steueroasen-Abwehrgesetz (StAbwG) — a punitive layer that Cyprus, Panama or Paraguay exiters do not face. This guide walks the corridor with that asymmetry as the central planning constraint.
The Tax Delta at a Glance
| Germany (current) | Vanuatu (after move) | |
|---|---|---|
| Personal income tax | 14% to 42% progressive; 45% Reichensteuer above €277,826 | 0% — no personal income tax statute exists |
| Solidarity surcharge | 5.5% on income tax | None |
| Church tax | 8–9% of income tax | None |
| Capital gains / dividends | 25% Abgeltungsteuer + Soli = 26.375% flat | 0% on all gains and dividends, foreign and domestic |
| Foreign rental, interest, royalties | Worldwide on unbeschränkt Steuerpflichtige | 0% — no income-tax base at all |
| Wealth / inheritance / gift | 0% wealth (suspended 1997); 7%–50% Erbschaftsteuer | 0% inheritance, 0% gift, 0% wealth, no exit tax |
| Corporate tax | 15% KSt + ~14–17% Gewerbesteuer = ~30% combined | 0% on offshore activity (International Companies); revenue raised via 15% VAT and licence fees |
| VAT | 19% standard | 15% VAT standard |
| Worldwide vs territorial | Worldwide (unbeschränkte Steuerpflicht) | No income tax at all — concept of territorial vs worldwide is moot |
| Effective rate (typical entrepreneur on €1M offshore income) | ~26.4% on dividends/gains, up to 47.5% on active income | 0% personally, in full |
The right-hand column lands in full only after three legs close: cessation of unbeschränkte Steuerpflicht under §1 EStG, settlement (or instalment election with Sicherheitsleistung) on the §6 AStG Wegzugsteuer, and a Vanuatu passport plus genuine substance file that survives §138 AO scrutiny.
Step-by-Step Move
Step 1: Confirm you can legally cease German tax residency under §1 EStG
German worldwide tax liability under §1 EStG is anchored in §§ 8 and 9 of the Abgabenordnung. You are unbeschränkt steuerpflichtig if you hold either a Wohnsitz under §8 AO — a dwelling kept and used under circumstances suggesting you will retain and use it — or a gewöhnlicher Aufenthalt under §9 AO, generally presumed at six months / 183 days of continuous presence. The Finanzamt applies the Gesamtbild der tatsächlichen Verhältnisse — the overall picture — and the Bundesfinanzhof has held that availability and intent to use a dwelling, not nights actually slept there, drive the §8 AO test.
Vanuatu makes this severance harder than any EU exit because Vanuatu CBI imposes zero physical-presence obligation: a German DSP-applicant can hold the Vanuatu passport without ever setting foot on the islands. That is a feature for mobility but a liability for the Finanzamt’s Gesamtbild analysis. A founder with a Vanuatu passport, a Hamburg apartment “kept for visits”, and 200 days a year circulating between Singapore, Dubai and Lisbon is not — on those facts — non-resident for German purposes; the dwelling and the absence of any competing day-count anchor combine to preserve §8 AO Wohnsitz. The defensive posture is strict: sell the German residence outright (or sign an arm’s-length 12+ month lease to a third-party tenant at market rent), Abmeldung at the Bürgeramt with a non-German address, terminate Krankenkasse, Rundfunkbeitrag (GEZ), Stadtwerke, IHK, Vereine and any Mitgliedschaft implying continuing presence. Move family and Hausrat physically. Furniture in storage with a German postal redirect is read as residual Wohnsitz in audit. And — because Vanuatu has no minimum-stay rule to point to as competing residency — establish a second jurisdiction with a real day-count footprint (UAE 90/180 day rule, or genuine 183+ days physically in Vanuatu under the retiree visa) so the Finanzamt sees an affirmative tax home elsewhere, not an open-ended Weltbürger profile.
Step 2: Plan around §6 AStG Wegzugsteuer — and the Sicherheitsleistung
Germany’s exit tax under §6 of the Außensteuergesetz is the single most expensive item on the Germany-to-Vanuatu corridor. It applies on the day you cease unbeschränkte Steuerpflicht to anyone who (a) holds at least 1% of the share capital of any corporation — German GmbH/AG or foreign Ltd, S.A., Inc. — and (b) was unbeschränkt steuerpflichtig for at least 7 of the last 12 years before departure. Both conditions must be met; the 7-of-12 threshold replaced the prior 10-of-11 rule under the ATAD-Umsetzungsgesetz from 1 January 2022. Where the trigger fires, the Finanzamt deems the shares sold at fair market value at the departure date and taxes the unrealised gain under the Teileinkünfteverfahren — 60% of the gain at marginal rate plus 5.5% Soli — producing an effective rate of roughly 28% of the gain for top-bracket exiters.
For a Vanuatu move all of the EU/EEA softening features of §6 AStG are off the table. The reformed §6 Abs. 4 AStG provides for payment in seven equal annual instalments regardless of destination, but for non-EU/EEA exits the Finanzamt routinely demands a Sicherheitsleistung of up to 100% of the assessed Wegzugsteuer — typically a German bank guarantee, pledged listed securities on a German-custodied account, or a Grundschuld over German real estate — before the instalment plan is granted. A founder with a €10M deemed-disposal gain therefore faces a roughly €2.8M security demand on departure even if the cash itself is staged over seven years. The §6 Abs. 3 Rückkehrerregelung — return to Germany within 7 years to undo the assessment — exists in theory but is incompatible with a credible Vanuatu exit.
Mitigations that materially work for Vanuatu-bound founders:
- Restructure GmbH → KG or GmbH & Co. KG before exit. Partnership interests sit outside §6 AStG. Build the seven-year clock on a partnership structure if Vanuatu is more than a passing thought.
- Roll qualifying shares into a German Familienstiftung or treaty-protected EU holding before departure, shifting the taxpayer of record off the natural person.
- Time the departure to a low-valuation window — §6 AStG fixes FMV on the day, and a soft year saves seven figures of cash tax.
- Stay below 1% through pre-departure dilution where the holding is borderline.
- Negotiate the Sicherheitsleistung — Vanuatu-located assets are not accepted, but German-custodied securities, German bank guarantees and German real-estate Grundschulds frequently are.
Step 3: Establish Vanuatu citizenship — Development Support Program
Vanuatu’s residency and citizenship framework is the easy leg. The Development Support Program (DSP), run by the Citizenship Office of the Republic of Vanuatu and submitted exclusively through government-licensed agents, grants citizenship for life on a non-refundable contribution of US$130,000 (single applicant), US$150,000 (couple), US$165,000 (family of three), US$180,000 (family of four), plus due-diligence (~US$5,000 per adult) and licensed-agent fees (~US$15,000–25,000). Processing is 30–60 days from clean filing — the fastest CBI on the market — and there is no obligation to visit Vanuatu before, during, or after approval.
For a German exiter this speed is double-edged. The passport and Vanuatu tax-residency status arrive together; the substance file does not. To anchor Vanuatu tax residency credibly against §§ 8/9 AO scrutiny, German planners should pair the CBI with one of:
- The Self-Funded Retiree Visa, requiring verifiable foreign income of VUV 250,000/month (~US$2,000/month) transferred to a Vanuatu bank account — and 183+ days physical presence to anchor gewöhnlicher Aufenthalt in Vanuatu under Vanuatu’s domestic-presence test;
- The Investor Visa, where active business operation in Vanuatu produces commercial substance plus an annual permit;
- Or a paired second residency in a higher-substance jurisdiction (UAE, Cayman) used as the actual day-count home, with Vanuatu held purely as the citizenship anchor.
CBI applicants submit apostilled birth certificate, marriage certificate where applicable, Führungszeugnis (German police clearance) plus equivalents from every country of residence in the prior 10 years, certified passport copies, source-of-funds dossier (bank statements, share-sale contracts, business documents, German tax assessments where available), medical and HIV-test certificates, professional CV and references. The dossier is filed by a licensed agent; due diligence is contracted to international vetting firms. Letter of approval issues from the Citizenship Commission within ~30–60 days for clean files; the oath of allegiance can be administered at a Vanuatu embassy/consulate or by a visiting agent. Full destination-side mechanics are in Tax-Free Residency in Vanuatu.
Step 4: Confront the missing treaty and the EU non-cooperative-jurisdiction listing
Germany and Vanuatu have no comprehensive double tax convention and no Tax Information Exchange Agreement in force. Vanuatu does not appear on the Bundeszentralamt für Steuern’s DBA-Übersicht in any form. Combined with Vanuatu’s periodic appearance on the EU list of non-cooperative jurisdictions for tax purposes (Annex I of the Council conclusions), this produces a uniquely punitive German-side regime:
- Steueroasen-Abwehrgesetz (StAbwG, 2021). Where Vanuatu sits on the EU Annex I list in any tax year, the StAbwG layers four defensive measures over §49 EStG: denial of business-expense deduction for payments to Vanuatu counterparties (§8 StAbwG), expanded CFC-add-back (§9 StAbwG), heightened withholding (§10 StAbwG), and disallowance of dividend / disposal-gain participation exemptions (§11 StAbwG). These are punitive, not corrective — they bite even where the underlying transaction is commercial.
- §162 Abs. 4 AO — heightened cooperation duties. Taxpayers with business relations in non-cooperative jurisdictions face a reversed burden of proof: the Finanzamt may estimate income at the higher end of plausible ranges where documentation is incomplete.
- §138 Abs. 2 AO disclosure. Acquiring a participation in a Vanuatu entity, founding a Vanuatu permanent establishment, or holding signing authority over a Vanuatu account triggers a §138 AO notification to the German tax authorities within one month of the year-end — non-filing carries fines and triggers the heightened §162 estimate.
- No Article 4 tie-breaker. A Wohnsitz dispute opened two years post-departure is decided purely under §§ 8/9 AO. There is no permanent-home / centre-of-vital-interests / habitual-abode cascade to lean on.
- Source withholding stays at full domestic rates. German GmbH dividends paid to a Vanuatu-resident shareholder face the full 25% Kapitalertragsteuer + 5.5% Soli (effective 26.375%) at source — and where the StAbwG bites, the participation exemption is also denied. Interest, royalties and German rental income face the corresponding §49 EStG full domestic rates.
The practical workaround is structural: keep no operating substance in Vanuatu. Use Vanuatu purely as the personal citizenship and tax-status anchor, and locate operating companies, IP, banking and counterparties in jurisdictions with active treaties and clean EU/OECD lists — typically the UAE for operations, Singapore or Switzerland for prime brokerage, Cyprus or Malta for an EU holding. This is the standard pattern used by Vanuatu-citizenship founders and is precisely what the crypto founder residency guide describes.
Step 5: Plan around §2 AStG erweiterte beschränkte Steuerpflicht — the 10-year tail
Vanuatu has a 0% personal income tax rate — the lowest possible. It is the textbook Niedrigsteuerland under §2 AStG. The rule catches German nationals (or anyone who held German citizenship within the prior 10 years) who were unbeschränkt steuerpflichtig for at least 5 of the last 10 years before departure and who move to a country whose tax burden on the same income is less than two-thirds of the corresponding German burden. Vanuatu clears that threshold by definition.
The effect is that for 10 years following departure, German-source income — German rental, German GmbH dividends, German director’s fees, German pensions, German-source royalties and capital gains on disposal of German Kapitalgesellschaft shares — remains taxable in Germany at ordinary progressive rates rather than under the lighter §49 EStG limited-tax basis available to ordinary non-residents. The §2 AStG return is filed annually on Form ESt 1 C, alongside the §49 EStG limited-liability filing. Where the StAbwG also applies, the §2 AStG tax sits on top of the StAbwG punitive measures — the two regimes do not displace each other.
The strongest mitigations are structural and pre-departure: redomicile the holding company outside Germany, sell or partnership-convert German Mietshäuser, terminate German director and Steuerberater mandates, and shift the income mix toward genuinely third-country sources well before the §2 AStG clock starts. The §6 AStG decision and the §2 AStG decision are linked — an exiter who cleans up German-source income to defuse §2 AStG also reduces the Wegzugsteuer base by the same act.
Step 6: First-year compliance and the §4 ErbStG 5-year tail
In the German departure year, file a final Einkommensteuererklärung declaring worldwide income up to the departure date and German-source income only thereafter. The §6 AStG Wegzugsteuer assessment is filed on the same return, with the §6 Abs. 4 instalment election made explicitly and the Sicherheitsleistung negotiated in parallel. The §2 AStG return for years 1–10 is a separate annual filing on Form ESt 1 C, declaring all German-source income at ordinary rates. Where StAbwG measures apply, the corresponding StAbwG forms layer on top. §138 AO disclosures of any Vanuatu corporate or banking footprint are due within one month of the year-end.
Vanuatu first-year compliance is by design trivial: there is no annual personal tax return because there is no income tax. CBI holders have no ongoing renewal. Retiree-visa holders renew annually (~US$400–800). The genuine compliance work for a German exiter sits not in Vanuatu but in the contemporaneous-evidence file: lease, utility bills, banking, day-count records, Vanuatu RUC-equivalent registration where a retiree/investor visa is also active, plus the operational-substance file in whatever paired jurisdiction (UAE, Cayman) anchors physical presence.
The trap that catches Germans late is §4 ErbStG: a German national remains within the German Erbschaftsteuer net for five years after departure regardless of where the decedent or heirs live, taxing the worldwide estate at 7–50%. Vanuatu has no inheritance, gift or wealth tax, but a German national who dies in Port Vila three years after Abmeldung leaves a worldwide estate fully exposed to German Erbschaftsteuer. Pre-departure use of the €400,000 spouse / €400,000 per-child gift allowances and family-foundation structuring are the conventional workarounds; both must be set up well before the move.
Cost & Timeline
| Phase | Cost (USD) | Time |
|---|---|---|
| German tax planning + §6/§2/StAbwG modelling (pre-move) | $8,000–$30,000 | 2–4 months |
| §6 AStG Wegzugsteuer assessment (founders only) | Up to ~28% × FMV gain | Filed with departure return |
| Sicherheitsleistung / bank guarantee for instalment plan | ~1.5–2% of secured amount p.a. | Through 7-year instalment period |
| Final Einkommensteuererklärung + Abmeldung | $1,500–$5,000 | Filed by 31 July of following year |
| Vanuatu DSP government contribution — single applicant | $130,000 | One-off |
| Vanuatu DSP government contribution — family of four | $180,000 | One-off |
| Vanuatu due-diligence fee (per adult) | ~$5,000 | One-off |
| Vanuatu licensed agent / legal | $15,000–$25,000 | 30–60 days to passport |
| Optional: paired UAE / Cayman residency for substance | $10,000–$30,000 | 1–3 months |
| Optional: Vanuatu retiree visa for 183-day anchor | $1,000–$3,000 + $24,000 p.a. demonstrated income | 1–3 months |
| First-year §2 AStG + StAbwG return (years 1–10) | $3,000–$8,000 | Annual |
| Total year-1 effective cost (single founder, CBI only) | ~$160,000–$200,000 ex. Wegzugsteuer cash | 2–4 months to passport |
| Total year-1 effective cost (family of 4, CBI + paired UAE) | ~$220,000–$260,000 ex. Wegzugsteuer cash | 3–6 months to full structure |
The cost profile is the inverse of the Germany-to-Paraguay corridor: Vanuatu’s capital threshold is ~25× higher than Paraguay’s bank-deposit pathway, but the timeline is dramatically faster (passport in weeks rather than 21–24 months to permanent residency) and the substance pairing — UAE or Cayman — is what most Vanuatu exiters end up budgeting for anyway. The compounding factor for a Germany exiter is the §6 AStG Sicherheitsleistung, which can lock up an additional six- or seven-figure sum for the duration of the seven-year instalment regardless of destination.
Treaty Considerations
The defining feature of the Germany-Vanuatu corridor is that there is no double tax treaty, no Tax Information Exchange Agreement, and Vanuatu has appeared on the EU list of non-cooperative jurisdictions for tax purposes in recent years. Where Cyprus, Malta or Italy offer a German exiter a layered treaty safety net, and even Paraguay or Panama offer a unilaterally generous territorial system without punitive German add-ons, Vanuatu is the only major destination on this site that simultaneously triggers the Steueroasen-Abwehrgesetz.
The practical implications run in four directions. First, on the income side, German-source flows to a Vanuatu resident are taxed at full German domestic rates under §49 EStG, with the participation exemption denied where StAbwG bites, and §2 AStG pushing the rate up to ordinary progressive for 10 years. Second, on the residency side, a Wohnsitz dispute decided two years post-departure goes purely through §§ 8/9 AO without treaty assistance — meaning a contemporaneous evidence file and an affirmative second jurisdiction (UAE day-count, Cayman investor permit, Vanuatu retiree visa with 183+ days) is the only defence. Third, on the disclosure side, §138 AO notifications and §162 Abs. 4 AO heightened cooperation duties impose paperwork and reversed-burden risks not present on Cyprus or Malta exits. Fourth, on the inheritance side, §4 ErbStG runs for five years post-departure and there is no treaty mechanism to displace it.
The compensating fact is that Vanuatu’s 0% regime is unilaterally generous on the inflow side — there is no Vanuatu tax to credit against, in the first place. Double taxation in the strict sense rarely materialises; the risk that does is single-sided punitive German taxation on items the Finanzamt and the StAbwG can still reach.
Common Mistakes
- Treating Vanuatu like an EU exit. No treaty, no TIEA, no §6 Abs. 4 EU instalment relief without Sicherheitsleistung, no Article 4 tie-breaker, and the Steueroasen-Abwehrgesetz on top. The planning checklist is materially longer than for Cyprus or Malta — and longer than for Paraguay or Panama.
- Holding the Vanuatu passport without a real day-count anchor. The passport itself is not residency. A Hamburg apartment kept “for visits” plus a Vanuatu passport plus 200 days of circulating travel is exactly what the Finanzamt reads as preserved §8 AO Wohnsitz.
- Locating operating substance in Vanuatu. As long as Vanuatu sits on the EU Annex I list, payments to Vanuatu counterparties lose deductibility under §8 StAbwG, dividends from Vanuatu entities lose participation exemption under §11 StAbwG, and CFC add-backs widen under §9 StAbwG. Use Vanuatu for the passport — operate elsewhere.
- Skipping §138 AO disclosures. Acquiring a Vanuatu entity, opening a Vanuatu bank account with signing authority, or founding a Vanuatu PE all require notification to the German Finanzamt within one month of the year-end. Late filing triggers fines and §162 Abs. 4 AO heightened-cooperation estimates.
- Triggering §6 AStG by accident. Founders who restructured to a partnership and converted back to a GmbH within seven years of departure, or who crossed the 1% threshold via secondary purchases, walk straight into Wegzugsteuer.
- Underestimating the Sicherheitsleistung. The 7-year instalment is not free for non-EU destinations; budget the bank-guarantee cost into the year-1 model, and remember that Vanuatu-located assets cannot post the security.
- Ignoring §4 ErbStG and §2 AStG. Vanuatu has 0% inheritance and 0% income — but Germany continues to tax worldwide estates of German nationals for 5 years and German-source income at ordinary rates for 10 years post-departure.
FAQ
Will I still have to file a German tax return after moving to Vanuatu?
Yes. For the departure year, a final Einkommensteuererklärung covering worldwide income to the departure date and German-source income only thereafter. Then for 10 years following departure, an annual §2 AStG return on Form ESt 1 C, taxing German-source income at ordinary progressive rates because Vanuatu is a Niedrigsteuerland under §2 Abs. 2 AStG. Where Vanuatu sits on the EU Annex I list in any given year, additional StAbwG forms layer on top. §138 AO disclosures of any Vanuatu corporate, banking or PE footprint are due within one month of year-end.
Does the §6 AStG Wegzugsteuer apply if I move to Vanuatu?
If you hold ≥1% of any corporation and were unbeschränkt steuerpflichtig for at least 7 of the last 12 years, yes. The substantive rule is destination-neutral. As a non-EU/EEA exit, Vanuatu triggers a Sicherheitsleistung demand alongside the seven-year instalment plan, and the §6 Abs. 3 Rückkehrerregelung is practically unusable.
Is there a tax treaty between Germany and Vanuatu?
No. Neither a comprehensive double tax convention nor a Tax Information Exchange Agreement is in force between Germany and Vanuatu. German-source withholding on dividends, interest and royalties paid to Vanuatu residents stays at full domestic rates, and there is no Article 4 residency tie-breaker if the Finanzamt opens a Wohnsitz audit.
What is the Steueroasen-Abwehrgesetz and does it apply to me?
The StAbwG (2021) imposes punitive measures on transactions with counterparties in jurisdictions on the EU Annex I non-cooperative list. Vanuatu has appeared on that list in recent years; status is reviewed twice a year and should be checked annually. Where it applies, expense deductions are denied (§8), CFC add-back widens (§9), withholding hardens (§10), and dividend / disposal-gain participation exemptions are disallowed (§11). The clean structural answer for Germany-to-Vanuatu exiters is to keep operating activity outside Vanuatu — passport in Vanuatu, operations in UAE, Cayman, Singapore or an EU holding.
Do I have to spend any minimum time in Vanuatu to keep the citizenship?
No. Vanuatu CBI imposes zero physical-presence requirement before, during, or after approval. The passport is granted for life with no renewal that re-tests eligibility. Standalone, however, the absence of day-count is also the corridor’s biggest §§ 8/9 AO weakness — anchoring tax residency credibly against the Finanzamt typically requires either 183+ days physically in Vanuatu (retiree-visa route) or a paired residency in a higher-substance jurisdiction (UAE, Cayman) with its own day-count footprint.
How is my German GmbH dividend taxed after the move?
The dividend faces full German Kapitalertragsteuer (25%) + Soli (5.5%) = 26.375% withholding at source under §49 EStG, with no treaty reduction (because there is no treaty). §2 AStG may push the German treatment back to ordinary progressive rates plus Soli for the first 10 years. Where StAbwG applies, the participation exemption on disposal gains of the GmbH shares is also denied.
How long does the full Germany-to-Vanuatu move take?
Realistic timeline 2–4 months from first planning meeting to Vanuatu passport — the fastest end-to-end CBI exit in the German corridor. Adding a paired UAE or Cayman residency for substance extends to 4–6 months. The German departure return, §6 AStG assessment and Sicherheitsleistung negotiation run in parallel.
How does Vanuatu compare to St. Kitts & Nevis or the UAE for a Germany exiter?
St. Kitts & Nevis wins on passport mobility (broader Schengen access on a stable basis) but is slower (4–6 months) and more expensive (US$250,000 minimum), and has historically not appeared on the EU Annex I list. UAE wins as a substance jurisdiction — an active treaty network, a credible 90/180 day residency rule, banking and operational infrastructure — and is most often paired with Vanuatu rather than chosen instead of it. Vanuatu’s unique value is the 30–60 day passport timeline; for German founders who want a second citizenship locked in fast, with the operating life remaining elsewhere, no other jurisdiction matches it.
Next Step
For the full destination-side breakdown, see Tax-Free Residency in Vanuatu. For the broader exit-tax framework across all major origin countries, see How to Legally Exit a High-Tax Country. For the day-count rules that interact with §§ 8/9 AO, see The 183-Day Rule Explained. For the operational pairing, see Tax-Free Residency in the UAE and the Crypto Founder Residency Guide.
Book a free consultation — we specialize in Germany-to-Vanuatu relocations, §6 AStG instalment planning with Sicherheitsleistung negotiation, the §2 AStG / StAbwG / no-treaty interaction, and the paired-residency structures that make Vanuatu credible against §§ 8/9 AO scrutiny.
Last updated: 2026-04-27
Sources:
– Bundesministerium der Finanzen — Außensteuergesetz §§ 2, 6 (https://www.gesetze-im-internet.de/astg/)
– Bundesministerium der Finanzen — Steueroasen-Abwehrgesetz (StAbwG) (https://www.gesetze-im-internet.de/stabwg/)
– Bundeszentralamt für Steuern — Übersicht der Doppelbesteuerungsabkommen (Vanuatu not listed) (https://www.bzst.de/DE/Unternehmen/Internationales/Doppelbesteuerungsabkommen/doppelbesteuerungsabkommen_node.html)
– Council of the European Union — EU list of non-cooperative jurisdictions for tax purposes (https://www.consilium.europa.eu/en/policies/eu-list-of-non-cooperative-jurisdictions/)
– Citizenship Office of the Republic of Vanuatu — Development Support Program (DSP)
– PwC Worldwide Tax Summaries — Vanuatu & Germany (https://taxsummaries.pwc.com/vanuatu, https://taxsummaries.pwc.com/germany)
– KPMG — Germany Country Tax Profile (Wegzugsteuer & §2 AStG): https://kpmg.com/de/en/home/insights/2022/08/atad-umsetzungsgesetz.html