Tax from the perspective of Germany, Austria and Switzerland
What the home tax office examines when a company sits abroad: management, permanent establishment, CFC rules, exit tax. With statutory sources.
Place of management: how to run your foreign company on a sound tax footing
The place of management follows the person who makes the decisions. If you live abroad and work from there, you run your company from there too. This article shows how the place of management becomes visible, why a registered office and agent do not have to move it, and how to set up a US LLC or an EU company at your new home on a sound tax footing.
30 October 202617 min
CFC taxation: when it applies and how to set up your foreign company correctly
Majority stake, passive income, tax below 15%: only when all of these come together does Germany attribute a foreign company’s profits to the shareholder. This article explains the rule in plain language, works through an example before and after a move, and shows the three routes to set up your structure properly.
21 September 202616 min
Double taxation treaties: how to use a treaty after your move
Once you are resident in your new country, the double taxation treaty works for you. Using the OECD Model Convention, this article explains how residence, business profits, dividends and royalties are allocated, works through a dividend before and after the move, and shows how the US LLC and EU companies at your new home fit in.
30 October 202616 min