Question Optimize tax for high income self-employed software dev in Austria

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Marzio

Rainmaker
Entrepreneur
If I am not mistaken, a Cyprus construct would work well.

Not in his case since he is the developer and work is performed in Austria.

However the thing that make the Cyprus contruct work is paragraph 8 of article 7 of the DTT between Cyprus and Austria that says "(8) The term "profits" as used in this Article shall include profits of a partner from his participation in a partnership, including participation in a a silent partnership."

If you look at the DTT between Cyprus and Hungary you'll see that there's paragraph 6 of article 7 that says "(6) The provisions of this Article shall also apply to shares in profits arising from participation as a silent partner in an enterprise."

OP should seek professional tax advice but that line could mean that if he goes and form a company in which he is only an investor and job is performed through a permanent establishment in Hungary, he could potentially pay only 9% CIT in Hungary and then as per paragraph 6 "shares in profits arising from participation as a silent partner in an enterprise" should be tax free but i'm 100% speculating.

Obviosly OP should hire somebody in HU and rent an office BUT he potentially could commute to Sopron which is one hour drive from Wien, cross the border without anybody knowing and perform the work himself alongside the employee.
 

domperignon

New member
Not in his case since he is the developer and work is performed in Austria.

However the thing that make the Cyprus contruct work is paragraph 8 of article 7 of the DTT between Cyprus and Austria that says "(8) The term "profits" as used in this Article shall include profits of a partner from his participation in a partnership, including participation in a a silent partnership."

If you look at the DTT between Cyprus and Hungary you'll see that there's paragraph 6 of article 7 that says "(6) The provisions of this Article shall also apply to shares in profits arising from participation as a silent partner in an enterprise."

OP should seek professional tax advice but that line could mean that if he goes and form a company in which he is only an investor and job is performed through a permanent establishment in Hungary, he could potentially pay only 9% CIT in Hungary and then as per paragraph 6 "shares in profits arising from participation as a silent partner in an enterprise" should be tax free but i'm 100% speculating.

Obviosly OP should hire somebody in HU and rent an office BUT he potentially could commute to Sopron which is one hour drive from Wien, cross the border without anybody knowing and perform the work himself alongside the employee.
Thank you for the reply.

Any advice on how to find good tax advice on such matters?
 

bigdaddyleon

Active Member
the video is about the fact that if you move abroad from Germany and then come back after a few years with the sole proprietorship, that you can write it off over the years.

Nevertheless, during the time abroad, the entrepreneur must pay tax on his profit in the respective country where he is located for the years.
 

RealDude

Entrepreneur
the video is about the fact that if you move abroad from Germany and then come back after a few years with the sole proprietorship, that you can write it off over the years.

Nevertheless, during the time abroad, the entrepreneur must pay tax on his profit in the respective country where he is located for the years.
After 1 year in his example.
 

JimBeam

Entrepreneur
Habibi, come to Dubai!
Here you'll pay 0% tax and you can keep all the money you make.

I'n most parts of Europe you'll give to the government at least 25%.
So that's money wasted and you get basically nothing in return and in your case that's minimum 100k/year.

In here you can keep those 100k/year use that money to rent a nice apartment or home, buy a car, eat well etc.
And the best part - you don't have to even think about filing for tax.
 

tolstoy

BANNED MEMBER
Hi,

What options do I have for tax optimizations living in Vienna, Austria?

Income from freelance software development ~$400,00K / year
Its easy work with a third party company like a seychelles ibc to accept the money(payments through their invoice) and ask them to send you crypto for a percentage - you are sorted mate. If you need any further help let know. No need to move anywhere and complete peace of mind.
 

FantomOffshore

Active Member
Hi,

What options do I have for tax optimizations living in Vienna, Austria?

Income from freelance software development ~$400,00K / year
With that kind of money why not just try and move to Switzerland? Seems like path of least pain. Half a year in Schweiz, half a year in Austria.
 

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