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[…]
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.
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.