Case examples
Four cases.
No gloss.
Starting position, decision, costs and pitfalls. The cases are anonymised composites of typical engagements; they are not client quotes and not promises of results.
4 cases · as of 17 September 2026
At GCS, what a case costs is on the country page, not in the quote. The examples therefore name the package prices and say what comes alongside. Where a plan did not work, that is stated too.
01 · United States
Software provider from Bavaria: a US LLC as his permanent company, residence in Dubai
A sole trader from Bavaria wanted less bureaucracy, a free choice of where to live and a company customers worldwide recognise. He moved to Dubai and has run a Wyoming LLC since.
€1,800Formation package€1,200from year 2
Starting position
- Sole trader from Bavaria selling software subscriptions and development services. His customers are in Europe, North America and Asia and increasingly pay in US dollars.
- Annual revenue (assumption): EUR 150,000 to 200,000, growing. No shareholdings in corporations, no property, no employees in Germany.
- Goal: decide for himself where he lives and pays tax, with a lean company that works online. The family is not tied to one place, and he serves his customers remotely anyway.
- First assessment: as long as he lives and decides in Germany, the profits are taxed in Germany. The LLC’s advantage comes with the move.
Decision
- GCS recommended the US LLC as the permanent structure and residence in the United Arab Emirates, which do not levy income tax on individuals. Cyprus with non-dom status was the alternative for life in the EU. The client chose Dubai.
- Order of steps: first his German tax adviser clarified the departure. No exit tax arose because he holds no shareholdings. Then came a home and residence permit in Dubai, giving up the German home, deregistration and the move.
- The company formed was a single-member LLC in Wyoming. It is transparent for US tax: the United States attributes its profits to the owner, and without US business activity there is usually no US income tax. The client is sole member and manager under the operating agreement. Contracts, invoices and account approvals have been handled from Dubai since.
- A UAE practitioner checked the local corporate tax for individuals conducting business beforehand. In his assessment no registration is required as long as turnover in the calendar year stays below AED 1 million; as the business grows, this is reviewed again (as of 09/2026).
- For the account, we prepared an application to a US payment provider: with the Dubai address, business model, customer contracts and source-of-funds evidence. A second payment route followed shortly after.
Costs
- The USA · LLC formation package: EIN application (the company’s US tax number), operating agreement, registered agent (the official contact for legal notices in Wyoming) and business address for twelve months. From the second year, basic administration.
- Government charge: the annual Wyoming license tax, starting at USD 60 (as of 09/2026). In the standard case, basic administration covers it.
- Form 5472 with the pro forma Form 1120, the annual information return for foreign-owned LLCs: the client booked the GCS service for it.
- Priced separately: German exit advice and the final German tax return, the UAE practitioner, bookkeeping, rent and residence permit.
Pitfalls
- Order of steps: the LLC was formed after the move, so its place of management was in Dubai from the start.
- A clean break: he gave up the German home rather than merely deregistering. A home still available to him would have kept German tax liability alive (section 8 AO).
- He no longer has substantial economic interests in Germany. His tax adviser reviewed extended limited tax liability before he left.
- Form 5472 runs through the GCS service, and the deadline is in the calendar.
- The account application went out complete, with business model, contracts and source-of-funds evidence.
Outcome. The whole process took a few months. The LLC was registered shortly after his arrival in Dubai, and the account followed after the provider’s review. The client received formation documents, EIN, access credentials and a calendar with the Wyoming annual report and Form 5472. Today he works location-independently for customers on three continents; bookkeeping and filings sit with him and his practitioners.
02 · Cyprus
Consultant from Vienna: relocating to Cyprus with non-dom status and her own Ltd
A management consultant from Vienna moved her centre of life to Cyprus and formed a Ltd there, in the order professional advisers, deregistration, formation.
Starting position
- Management consultant from Vienna, previously a sole trader, with clients in Austria, Germany and the Middle East.
- Annual revenue (assumption): EUR 200,000 to 300,000 in project fees. In addition, a private securities portfolio.
- Goal: genuinely move her centre of life to Cyprus, run the company from there and bring Austrian tax residence to a clean end.
- No home kept in Austria. The family moves with her.
Decision
- Order of steps, as GCS recommends it: the client first engaged an Austrian tax adviser and a Cypriot practitioner, meaning a tax adviser or lawyer licensed there. In Austria they reviewed separately what the departure means for the sole-trader business and the portfolio. Only then came deregistration and the move, and last the formation.
- Residence under the 60-day rule. Under it, 60 days of presence in Cyprus per year are enough, provided every other statutory condition is met. Those are: a home, documented days of presence, a business connection through the Ltd, no more than 183 days in any other state and no tax residence in any other state. She applied for non-dom status, the Cypriot special regime for newcomers. Her residence history passed the 17-of-20-years test: she had been tax resident in Cyprus for fewer than 17 of the last 20 years.
- The choice was a Ltd with the client as resident director and a registered office, the company’s official seat. As sole shareholder she also acts as company secretary, the officer the law requires; Cypriot law allows this with a single shareholder. Resolutions, contracts and banking take place in Cyprus.
- Deliberately not done: no nominee director, meaning no third party who runs the company on paper only. No formation before deregistration. No IP-box planning, meaning no reduced tax on income from patents and software, because there are no development profits that would qualify.
Costs
- The Cyprus · Ltd formation package: tax registration and registered office for twelve months plus preparation of the banking documents. From the second year, basic administration.
- Residence planning as a separately agreed service: residence evidence, the non-dom application and coordination of the practitioners in both countries.
- Priced separately: Austrian exit advice, the Ltd’s bookkeeping and accounts, rent and insurance. Plus GESY contributions, the payments into the Cypriot health system, 2.65% on specified passive income (as of 09/2026).
Pitfalls
- Forming before the move would have created a Ltd initially managed from Vienna. It would therefore have been tax resident in Austria.
- Deregistration alone does not end Austrian tax liability. The home, the portfolio and the sole-trader business were wound up or classified by the practitioner before departure.
- Too few days in Cyprus, or tax residence in another state, would have defeated the 60-day rule. The client therefore keeps a presence log.
- Non-dom status concerns specified income and levies, chiefly dividends and interest. Her salary as director is subject to ordinary Cypriot income tax.
Outcome. Deregistration, the move and the formation followed in that order over roughly six months. The client received residence evidence, company documents and a calendar for days of presence, filings and the continuation of non-dom status. Annual tax returns, the Ltd’s bookkeeping and the assessment of new income sit with her and her practitioners in Austria and Cyprus.
03 · Estonia
Enquiry from North Rhine-Westphalia: an Estonian OÜ run from a home office, and why we advised against it
An online-marketing provider wanted to save tax by forming an Estonian OÜ through e-Residency and managing it from his home office in Germany, and we did not form it.
Starting position
- Sole trader from North Rhine-Westphalia providing online-marketing services. His customers are almost all in Germany.
- Annual revenue (assumption): EUR 100,000 to 150,000. No employees, no connection to Estonia.
- Goal: form an OÜ, the Estonian limited company, through e-Residency, Estonia’s digital access card. Retain profits and thereby lower the German tax bill. Home, office and customers were to stay as they are.
- Expectation: Estonia does not tax retained profits annually, so overall tax would fall.
Decision
- The review focused on the place of management, meaning the place where the decisions are taken (section 10 AO). Every decision would have been taken in the home office in Germany. In the German tax adviser’s assessment, the OÜ would therefore have been fully liable to German corporate income tax, paying it on its entire profit. Trade tax would have come on top, for the permanent establishment, meaning the fixed place of business in the home office. Its registration in Tallinn would have changed nothing.
- Result: no saving. Instead, filing and notification duties in two countries and a company that counts as resident in both. That dual residence would first have to be settled under the double tax treaty, the tax agreement between Germany and Estonia.
- The recommendation was the route GCS normally recommends: move the centre of life first, then form. For a location-independent one-person business, four routes would come into question: the US LLC with residence in a country without income tax such as the United Arab Emirates or without a fixed residence, a move to Tallinn with an OÜ managed from there, Cyprus with non-dom status, or Bulgaria with residence and an EOOD. Non-dom is the Cypriot special regime for newcomers, the EOOD is the Bulgarian limited company. GCS offers the residence planning for this, covering deregistration, exit consequences and residence, and forms the company once the residence is in place. The exception would be genuine substance in Estonia while resident in Germany: management, decisions and staff on the ground. For this business, that would be disproportionate.
- Without a move, the only option was not to form. The real question went to his tax adviser: how can he retain profits more cheaply at home? Deliberately not done: no formation engagement, no contact person or registered address as a substitute for substance, no e-Residency application.
Costs
- Only the planning was engaged. The formation package was not triggered and no basic administration arises.
- For comparison, what would have arisen: the registry fee of EUR 265 (as of 09/2026) as part of the formation package, the e-Residency application fee, address and contact person. Plus Estonian bookkeeping and the annual report, on top of the German returns.
- Incurred separately: the classification by the German tax adviser.
Pitfalls
- The place of management follows where decisions are actually taken, not the registered address. That is why the move comes first.
- A company managed from Germany is declared and taxed in Germany. The advantage of a foreign company only comes with the move.
- Duplicate duties: the Estonian annual report is due even while the company is dormant. On top come the German returns and the notification of the foreign shareholding to the tax office (section 138(2) AO).
- The e-Residency card is often mistaken for residence. It is only a digital access credential and changes nothing about personal tax liability.
Outcome. The client did not form a company but received a written assessment: move residence first, then form, with the countries that would fit and the offer to plan both in that order. Whether he moves is his decision. Until then, the retained-profits question stays with his tax adviser at home, and the tax assessment of each route rests with the practitioners in both countries.
04 · Poland
Entrepreneur from Zurich: a Sp. z o.o. for a development team in Poland
The owner of a Swiss IT company built a permanent team in Poland and chose a Sp. z o.o. with a local managing director instead of further freelance contracts.
on requestFormation packageon requestfrom year 2
Starting position
- Owner of a Swiss AG providing IT services, based near Zurich. His residence remains in Switzerland.
- Building a team of initially five to eight developers in Poland (assumption). Until now this ran through individual freelance contracts.
- Group revenue (assumption): CHF 2 to 3 million. The Polish company is to provide development services to the Swiss AG.
- Goal: employment under Polish law, a separate liability layer and no disguised employment, meaning no freelancers who legally count as employees.
Decision
- JDG and Sp. z o.o. were compared, meaning the Polish sole-trader form and the Polish limited company. The JDG was ruled out: the owner is personally liable, and it does not fit a business with employees and a sister company in Switzerland.
- The choice was a Sp. z o.o. with the client as shareholder. Because he stays resident in Switzerland, this case is the exception to the order GCS otherwise recommends. It works only with genuine substance in Poland: a managing director resident in Poland runs the company, the team is employed there, and resolutions and contracts are made in Poland. The client exercises his shareholder rights but does not manage the business.
- Share capital of PLN 5,000 was paid in. Full accounting, payroll and registration with ZUS, the Polish social insurance body, run from day one through a Polish accounting firm. Charging services to the Swiss AG is supported by transfer-pricing documentation, meaning the evidence that prices between the sister companies are at market level. Practitioners in both countries provide it.
- The reduced 9% CIT rate, meaning the lower Polish corporate income tax, was planned as a possibility, not as the basis of the model. It applies only to eligible small or new taxpayers within the revenue thresholds. Estonian-style CIT, the Polish option of taxing profits only on distribution, was reviewed and deferred until the distribution policy is settled. Deliberately not done: no intermediate holding company.
Costs
- The Poland · Sp. z o.o. formation package (price on request): incorporation, initial filings, tax registration and a business address for twelve months. From the second year, basic administration.
- Share capital of PLN 5,000 (as of 09/2026): this is company capital, not a fee.
- Priced separately: full accounting, payroll and ZUS contributions, the managing director’s remuneration, office space, transfer-pricing documentation and the Swiss fiduciary.
Pitfalls
- Management from Zurich would have moved the place of management, meaning where decisions are taken, to Switzerland. The structure would have lost its purpose. Hence a local managing director who actually decides.
- Further freelance contracts instead of employment: risk of disguised employment and back-payment of social contributions.
- Budgeting with 9% without eligibility: the revenue threshold and exclusions, for example for capital gains, would have led to 19%.
- Charging the Swiss AG without documentation: the tax authorities of both countries could then adjust the transfer prices.
Outcome. The Sp. z o.o. was registered, the team is employed and the accounts are kept by the Polish firm. The client received the articles, register extract, tax numbers and a calendar with accounts, ZUS and register deadlines. The assessment of the shareholding in Switzerland, transfer pricing and the Polish returns sit with his fiduciary and the Polish practitioner.
The examples describe processes, not results that transfer. Whether a structure fits you depends on your activity, your residence and the review by the professionals you appoint.
