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Tax residency and the 183 days rule

so what about the principle of taxation in place of control(ie. incorporated in Spain but owned and managed by German owner in Germany)? that's how world works, usually. how come these countries say otherwise? I mean, this was the old way but to prevent tax evasion and whatnot it has been changed to tax in the country of control, not in country of incorporation.

(i am just trying to learn here)
 
Each country's laws are different, both in how they are written and in how they are enforced, but in most cases you can solve it with a tax treaty to establish a single tax residence or at least a single location where income/profits are earned.

But if you're a German with a German company moving down to Malta or Cyprus to save on taxes, seriously consider the pros/cons of starting a new company vs. continuing to operate your German one.