Not every foreign company and not every retained profit leads to CFC taxation. The conditions to be examined together.
Which shares § 6 AStG covers, which tax hours count and why operating assets require a separate examination of the de-tricking.
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.
Pre-tax reimbursement, research funding and profit taxation have different effects. I show which calculation is necessary before a combination of several countries.
Anyone who has a company audited abroad in 2026 should first arrange responsibility, place of management, substance, bankability and documentation.
Exit tax does not affect every departure. Crucial are investments, investment shares, residence, place of management and technically tested structure.
Holding models often sound strong. This contribution ranks administrative burden, place of management, bankability and countries risk before implementation.
A foreign company must fit into place of management, activity and documentation. The Budapester shows which questions should be clarified before the foundation.
A company abroad is not a product off the shelf. Decisive are activity, management, ownership, processes and the actual goal of the entrepreneur.
