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Question Cheap setup for low turnover

trafficjunky

New member
Mar 10, 2023
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Germany
I've started doing an affiliate marketing apart from my fulltime job time and came to 2-3k EUR extra income monthly, as i have a full time job i don't want to spend them right now(and don't want to get taxed for them right now), rather accumulate them for couple years while them in crypto.

So i'd like to incorporate a company, probably somewhere outside EU.
i've spend some time reeding threads and understood that opening a bank(or even EMI) would be challenging and expensive as hell, but maybe i'm missing something out.
Is incorporating the company and dealing with the account opening even worth with my 2-3k EUR monthly revenue? if so, which jurisdictions and banks/EMIs you'd recommend?

I'm German citizen, jurisdiction may not be anonymous and i'm planning to lose German personal tax residency(by moving to some other country for a 6+ months) before paying out dividends out of the company
 
I'm German citizen, jurisdiction may not be anonymous and i'm planning to lose German personal tax residency(by moving to some other country for a 6+ months) before paying out dividends out of the company
Be aware of the German exit tax (Wegzugsbesteuerung) applicable to dominant shareholders of GmbHs and comparable foreign companies. Since 2022 the tax will no longer be deferred even if you move within the EU (though the ECJ may declare that invalid once again, it's still the current law).

It may depend on whether a LLC is considered a "Kapitalgesellschaft" by the German authorities, but I wouldn't risk it.
 
Be aware of the German exit tax (Wegzugsbesteuerung) applicable to dominant shareholders of GmbHs and comparable foreign companies. Since 2022 the tax will no longer be deferred even if you move within the EU (though the ECJ may declare that invalid once again, it's still the current law).

It may depend on whether a LLC is considered a "Kapitalgesellschaft" by the German authorities, but I wouldn't risk it.
 
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Be aware of the German exit tax (Wegzugsbesteuerung) applicable to dominant shareholders of GmbHs and comparable foreign companies. Since 2022 the tax will no longer be deferred even if you move within the EU (though the ECJ may declare that invalid once again, it's still the current law).

It may depend on whether a LLC is considered a "Kapitalgesellschaft" by the German authorities, but I wouldn't risk it.

thanks for the info
 
There's one more issue on the company level by the way, and that's arguably the bigger issue than your personal "Wegzugsbesteuerung": As you're currently a resident of Germany, the German authorities will probably take the position that management & control of the company is in Germany. That creates two problems:

1) German authorities will construe a permanent establishment of your company in Germany, will probably attribute any profits to that establishment, which will make all profits liable to taxation in Germany (15% KSt + Gewerbesteuer according to the municipality you live in). And you'll be on the hook for tax evasion if you don't declare it that way.
2) Once you move out of Germany, you'll want to make sure that either management & control or any demonstrably profit-generating activities *remain* in Germany. Otherwise, the *company* will be taxed as if it sold the profit-generating entities ("Entstrickungsbesteuerung").
 
There's one more issue on the company level by the way, and that's arguably the bigger issue than your personal "Wegzugsbesteuerung": As you're currently a resident of Germany, the German authorities will probably take the position that management & control of the company is in Germany. That creates two problems:

1) German authorities will construe a permanent establishment of your company in Germany, will probably attribute any profits to that establishment, which will make all profits liable to taxation in Germany (15% KSt + Gewerbesteuer according to the municipality you live in). And you'll be on the hook for tax evasion if you don't declare it that way.
2) Once you move out of Germany, you'll want to make sure that either management & control or any demonstrably profit-generating activities *remain* in Germany. Otherwise, the *company* will be taxed as if it sold the profit-generating entities ("Entstrickungsbesteuerung").
Thanks for bringing it up.
If i understand correctly i should consider moving to some low/zero personal tax country for a permanent residency? Are there such options in Europe or Asia available? or only caribbean countries?