Thanks again to everyone for the insights so far, I’ve taken some time to reflect and read up more, especially on the German CFC rules and how they apply to foundations and nominee setups.
I now fully understand that any structure managed from Germany, even indirectly, can trigger CFC and other reporting obligations. That’s why I’ve adjusted my approach:
-I intend to pay taxes in Germany while I’m still here
- I’m gradually preparing for relocation (within 1–2 years)
- I’d like to build a clean and professional setup that I won’t need to dismantle once I leave
So here’s my updated question:
What kind of structure would you recommend for someone still residing in Germany, paying taxes properly, but aiming to “bridge” into long-term offshore independence with a view to relocating soon?
Do I really need something like a Foundation and Nominees now, or would a simple IBC (fully declared) be sufficient for this transition phase?
Also, correct me if I’m wrong, but only setting up a local Gewerbe (sole proprietorship), without a proper structure (IBC, etc) in Germany might limit future flexibility due to things like “exit tax,” local bank account ties, and the need to rebuild infrastructure abroad.
I’d greatly appreciate thoughts, especially from those who’ve gone through a similar transition.
