Company foundation
Advice on the classification of active income...
How is active income classified by the tax authorities in accordance with the German Foreign Tax Act? Strategically, the question arises as to how active income is classified by the tax authorities in accordance with the German Foreign Tax Act. If you operate a foreign company in a low-tax country, you should, as already explained, generate "active income" in order to avoid add-back taxation in the country of residence of the shareholders of this company. The profits ...
Advice on structuring Classification of active income... Read More "
Advice on structuring: Strategic profit distributions...
In one of our previous articles, we already presented our "MORE-STUFF PLAN" for a possible relocation of the center of life abroad. The attentive and well-prepared online marketer, consultant and founder was provided with a comprehensive checklist. These serve as a tool for clarifying complex questions in the context of international tax law. Furthermore, questions for clarification were pointed out that arise in the middle of ...
Advice on structuring: Strategic profit distributions... Read More "
Double taxation NON-DBA clarification of facts...
How can I strategically deal with profit distributions from my foreign company? In one of our previous articles, we already presented our "MORE-STUFF PLAN" for a possible relocation of the center of life abroad. The attentive and well-prepared online marketer, consultant and founder was provided with a comprehensive checklist. These serve as a tool for clarifying complex questions in the context of international ...
Double taxation NON-DTA clarification of facts... Read More "
Double taxation - clarification of facts
How can I strategically deal with profit distributions from my foreign company? A double taxation treaty clarification: A foreign company that is classified under the CFC rules leads to add-back taxation in the country of residence of the shareholder of this company. As already explained, the profits of the foreign company are taxed at the income tax rate of the shareholders, who are natural persons, in the shareholder's country of residence. Strategically, the ...
Profit distribution strategy...
How can I strategically deal with profit distributions from my foreign company? In one of our previous articles, we already presented our "MORE-STUFF PLAN" for a possible relocation of the center of life abroad. The attentive and well-prepared online marketer, consultant and founder was provided with a comprehensive checklist. These serve as a tool for clarifying complex questions in the context of international ...
Strategic approaches if no DTA exists:
Double taxation agreements Double taxation agreements. Strategic approaches if there is no DTA. Just talk to us Double tax treaty What is a strategy if there is no double tax treaty (DTT) between the country of residence and the country of domicile of your foreign company? A foreign company that is classified under the CFC rules leads to add-back taxation in the country of residence of the shareholder of this company. As already explained, the profits of the foreign company are taxed in the ...
DBA consulting at the cutting edge....
What is the effect of a double taxation agreement (DTA) between your country of residence and the country in which your foreign company is based? In one of our previous articles, we already presented our "MORE-TRAVEL PLAN" for a possible relocation of the center of life abroad. The attentive online marketer, consultant and founder was provided with a comprehensive checklist. These serve as a tool for clarifying complex questions in the context of ...
Consultation: Countries without external tax laws
CFC Rules / Controlled Foreign Corporation in consulting practice: In today's issue, we look at a tax law nightmare. Anyone living in a country whose tax legislation contains "Controlled Foreign Corporation Rules" is severely restricted in the management of a foreign company. A foreign company that is classified under the CFC rules is managed in the shareholder's country of residence ...
Advice: How can add-back taxation be avoided?
In today's issue, we look at a tax nightmare and how to avoid add-back taxation. A foreign company that falls under the CFC rules will be subject to add-back taxation in the country of residence of the shareholder of that company. As already explained, the profits of the foreign company are taxed in the shareholder's country of residence for shareholders who are natural persons at ...