For Austrian Founders
Moving Your Company From Austria to Montenegro
Austria's top marginal rate sits at 55%. Before you get excited about the delta, know what the Wegzugsbesteuerung does to shareholdings over 1% on the way out — it's the number that actually decides whether this makes sense.
Read this before the rate comparison excites you
If you hold more than 1% of a corporation and give up Austrian tax residency, the Wegzugsbesteuerung treats your shares as sold at fair market value the day before you leave, taxed at the 27.5% KESt capital gains rate. Deferral without security (Ratenzahlung) is only automatic for moves within the EU/EEA — Montenegro is neither, so expect the Finanzamt to require the full amount within one month of departure unless a financial guarantee is posted. This has to be modeled against your actual company valuation before the rest of the pitch matters.
What Actually Changes
Where the savings come from
Progressive 9–15% corporate tax
Profit up to €100,000 is taxed at 9%; above that it's €9,000 plus 12% up to €1.5M, then 15% beyond — a fraction of what the same profit faces as Austrian personal income once drawn out.
A salary structure that keeps the gain
A properly built executive salary paired with the corporate rate keeps take-home income from quietly reverting to Austrian-style levels once you start drawing from the business.
EU accession, pre-EU prices
Montenegro is further along the accession track than most candidate countries, with living costs well under Vienna or Salzburg.
Coastal climate, no landlocked winters
Year-round Adriatic sun instead of Austrian winters, with a coastline Austria simply doesn't have.
Where This Won't Suit You
The Wegzugsbesteuerung, and other real friction
Exit tax on shares, due within a month
Moving outside the EU/EEA means no automatic interest-free deferral. The Finanzamt will typically expect payment within a month of departure unless you provide security, which changes the near-term cash picture for founders with an appreciated company.
Residency has to be real
Keeping an Austrian Hauptwohnsitz, family ties, or day-to-day management in Austria can keep you fully tax liable regardless of where your company is registered.
Banks are cautious, and slow
Montenegrin banks are risk-averse by regional standards. Opening a corporate account takes longer than it did at an Austrian bank.
Not Schengen access
A Montenegrin residence permit gives you the right to live and work in Montenegro. It doesn't replace the free movement an Austrian passport already gives you across the EU.
Want the exit tax and savings modeled together?
The corporate tax comparison only tells half the story until the Wegzugsbesteuerung number is on the table. Run the calculator, then talk to us about the full picture for your specific shareholding.
Not moving from Austria?