Hi everyone,
my current situation:
- Resident in Germany and UBO of my own company-GmbH, IT services provider without any employee (only me as Geschäftsführer/director)
- Income of the company 200K per year aprox
- No high personal expenses, so I assigned myself a low salary from the company
- In some years, I will move to my own country
- I want to invest the revenues of my own company in Real Estate (mainly in Spain) and in passive investment products (Funds, ETF), for the moment as a private investor
- Next new service: online courses, adsense and affiliates. I am still thinking how to handle it and avoid CFC regulation but I did not find any valid offshore alternative
- As company's revenue is very high, I am thinking to invest using my company.
Problem
- In some years, I will move to Spain, Since Germany will charge me and the assets of my company the Wegzugsbesteuerung (I think Expatration Tax would be the best translation) I am thinking how to bring all my assets with me
Idea
- I am thinking to found a holding company that collects all my investment assets during the next years till I retire, outside of Germany to avoid to pay Wegzugsbesteuerung.
- After reading many websites, I think the best ideas would be to set up a holding company in Cyprus, US LLC or directly in Spain (ETVE)
Spain: I think substance would not be a problem to be considered for German CFC rules, since I have relatives there that can managed the holding
Cyprus: Germany considers Cyprus as Niedrigsteuerland (low-tax country) so I think I need to assume more costs for maintaining the holding structure
US LLC: being honest I have read that it would be a good option for Real Estate but not really sure about advantages
Germany: Someone could think..."yeah, but setting up an offshore holding is much difficult, just found the holding company also in Germany and let it alive after you move to Spain". Yes, this could be also other chance.
Any other ideas?
- It would be also a nice to have to reduce corporate tax of my operative company in Germany - maybe providing some general services to my germany company from the offshore's holding), but I know it will be hard to do since the CFC rules limits the services invoices between companies owned by the same natural person (§ 8 Abs. 1 Nr. 5a AStG and § 8 Abs. 1 Nr. 5b AStG). Any ideas would be appretiated
Sorry if I have shared much details, I wanted to give as much information as possible. And sorry for my English!
my current situation:
- Resident in Germany and UBO of my own company-GmbH, IT services provider without any employee (only me as Geschäftsführer/director)
- Income of the company 200K per year aprox
- No high personal expenses, so I assigned myself a low salary from the company
- In some years, I will move to my own country
- I want to invest the revenues of my own company in Real Estate (mainly in Spain) and in passive investment products (Funds, ETF), for the moment as a private investor
- Next new service: online courses, adsense and affiliates. I am still thinking how to handle it and avoid CFC regulation but I did not find any valid offshore alternative
- As company's revenue is very high, I am thinking to invest using my company.
Problem
- In some years, I will move to Spain, Since Germany will charge me and the assets of my company the Wegzugsbesteuerung (I think Expatration Tax would be the best translation) I am thinking how to bring all my assets with me
Idea
- I am thinking to found a holding company that collects all my investment assets during the next years till I retire, outside of Germany to avoid to pay Wegzugsbesteuerung.
- After reading many websites, I think the best ideas would be to set up a holding company in Cyprus, US LLC or directly in Spain (ETVE)
Spain: I think substance would not be a problem to be considered for German CFC rules, since I have relatives there that can managed the holding
Cyprus: Germany considers Cyprus as Niedrigsteuerland (low-tax country) so I think I need to assume more costs for maintaining the holding structure
US LLC: being honest I have read that it would be a good option for Real Estate but not really sure about advantages
Germany: Someone could think..."yeah, but setting up an offshore holding is much difficult, just found the holding company also in Germany and let it alive after you move to Spain". Yes, this could be also other chance.
Any other ideas?
- It would be also a nice to have to reduce corporate tax of my operative company in Germany - maybe providing some general services to my germany company from the offshore's holding), but I know it will be hard to do since the CFC rules limits the services invoices between companies owned by the same natural person (§ 8 Abs. 1 Nr. 5a AStG and § 8 Abs. 1 Nr. 5b AStG). Any ideas would be appretiated
Sorry if I have shared much details, I wanted to give as much information as possible. And sorry for my English!
