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What’s the best offshore setup for German resident planning eventual relocation, but paying taxes meanwhile?

anceps

Mentor Group Gold
May 5, 2025
5
1
3
26
Germany
Hey everyone,

I’m a German resident currently operating a small digital business (freelance consulting, influencer marketing, and video services, 30k yearly).
I’m exploring offshore structuring to build a clean, professional setup that allows me to:

- Stay independent from Germany long-term
- Maintain privacy and international banking flexibility
- Eventually relocate abroad (in 1–2 years), at which point I’d fully exit the German tax system
- In the meantime: pay taxes in Germany properly

Initially, I was advised to go with a private Foundation + IBC structure.
Yes, I do want to pay taxes, because I understand that whatever structure I would have, the German IRS (Finanzamt) will catch me eventually, so I want to stay compliant, report income as required, but also build a long-term infrastructure I can keep using after leaving Germany.

So my core question is, what’s the smartest setup for someone in my position?

Do I really need a Foundation and nominees now, or would a single IBC (properly declared) be enough to get started?

Any providers you’d recommend who are honest and practical, I’d appreciate the input.


Thanks in advance!
 
If you directly or indirectly hold at least a 1% interest in a domestic or FOREIGN corporation, it will be subject to exit taxes.
I don't understand what you are trying to achieve with an IBC .
My long-term goal is to move abroad in the next 12–24 months, and I’d like to avoid building something in Germany (like a local "Gewerbe" structure or domestic company) only to have to shut it down and rebuild everything once I move.
Do you not think it would make sense to set up a simple, clean IBC now (fully declared in Germany), use it as my operating structure, and then "take it with me" once I leave the country?
 
30k per year in profit is not much. I doubt that there will be much exit tax as it is way lower than when a doctor closes his business. But the risk makes it not really attractive.

Of course, you can start complex setups etc. But it does not make much sense as many setups make sense if you live in X but not so much once you live in Y. At least for such small scales and a lot of personal work involved. You may want to start something in Cyprus with nominees or some US LLC with nominees (where you ideally use people from your environment that you can trust as nominees, noting that they best are digital nomads or live in South America / Africa where nobody cares).

And then see my previous post that your real question should be whether you can fly two years under the radar in Germany. Any IBC and whatever will not solve any of the imminent issues. The nominees do, but only insofar as that you don't work anymore, but the nominees did the consulting on paper.
 
What is your current setup? If you have a personal corporation right now (e. g. a GbR) § 17 EsTG does not apply. You could just move out first and than setup a newco abroad.