A company in its own country? Those who think across borders should first clarify purpose, responsibilities and actual place of management. Tax consequences belong in a professional examination.
A Hungarian holding company can bundle dividends from a German GmbH for further investments. However, a distribution without German withholding tax and tax-free dividends in Hungary are not an automatic[…]
Preparation for the exit tax belongs before the planned move. If changes to the company structure or shareholdings are planned, examination and implementation can take up to two years, depending[…]
Which shares § 6 AStG covers, which tax hours count and why operating assets require a separate examination of the de-tricking.
Not every foreign company and not every retained profit leads to CFC taxation. The conditions to be examined together.
Which equipment and which staff are suitable for the activity, where personal responsibility becomes apparent and when outsourced tasks exclude the proof according to § 8 (2) AStG.
I show how responsibilities, meetings, contracts and bank releases form a comprehensible chain of documents. What remains crucial is the actual place of management.
A US LLC does not replace a tax examination at residence. I show which documents for social contract, place of management and DBA belong together.
An account in Georgia does not replace a tax audit. I separate bank report, own declaration and participation in Germany, Austria and Switzerland.
Deregistration and travel days do not guarantee tax exemption. I show which questions about residence, income, place of management and bank access are clarified before the trip.