Thanks for the clarifications, since I don't think this is widely known (outside of entrepreneurial circles). That makes a lot of sense then.

So, as a "regular bloke" you can leave Germany for better pastures, no problem. But if you are "independently wealthy-ish", they really want to keep you there, to pay more taxes / employ people that pay taxes. Or take the money anyway, make sure they get their "capital gains taxes" so to speak?

25% capital gains tax is actually not that bad other than that Germany has no equivalent of an RRSP and TFSA. Capital gains are taxed as regular income in Canada for example. Your marginal tax rate is quite probably gonna be greater than 25%. To be fair, you only get taxed on half of the gains in many cases. Quoting https://www.wealthsimple.com/en-ca/learn/capital-gains-tax-c...:

As of June 25, 2024, however, you will be taxed on 50% of your annual capital gains up to $250,000. For any capital gains over $250,000, that ratio increases to two-thirds, or approximately 66.67%. Here’s how that would look in real life: Suppose one year you sell stocks for $300,000 more than you paid for them. 50% of the first $250,000 of those gains ($125,000) would be taxed as income. 66.67% of the remaining $50,000 ($33,335) would be taxed as well. So on the $300,000 gain, only $158,335 counts toward your taxable income.

For corporations and trusts, there’s no such threshold: regardless of the total capital gains, 66.67% are taxable

Like, if I was to sell my investments and move to Germany from Canada :) and let's say I had your 5 year example worth of 100k profit i.e. capital gains, to dispose of, even if you made zero other money that year for example would mean you pay $113,685 of taxes that year (in Ontario, just to make an example). That's an average tax rate of ~22.75%, marginal rate of ~53.5%.

Like it does sound like Canadian departure tax basically. And it's not just about companies as the example above shows. That was just me owning stocks. Any Canadian leaving has to pay departure tax. Basically, when you leave Canada you have to pay tax on any of your investments. A "deemed disposition". Pay taxes as if you had sold, even if you keep ownership. Which if you think about it, makes some sense. For all the country knows, you've accumulated wealth without ever paying capital gains tax, because you never sold and now you leave the country (potentially never to come back but who knows?!), and sell shortly after leaving. Leaving to a country with no capital gains taxes. A year later you come back and retire in Canada like you always planned. Deemed disposition prevents that. Makes sense actually. If you do stay in the other country afterwards, that's none of Canada's business any longer.

The good thing here is that we do have the RRSP and TFSA. So hopefully before leaving Canada I would've paid myself dividends over the years, in a tax efficient way and put those into a TFSA to grow tax free and I won't have to pay departure tax on that (or anything in an RRSP). And an RRSP would AFAIK even be tax sheltered as a "retirement account" under Canada - Germany tax treaties.

(fun thought experiment to move from each of these countries to the other :) )