I don't have any experience with the intricacies of dealing with
Germany's tax code, but I have been through the ringer with the US'
IRS and HK's IRD. I would very strongly advise you
against starting a new company in
Hong Kong. You will have to prove that you are compliant with every box that needs to be checked to qualify for tax-free status every year. As was mentioned earlier in the thread, proving this to the IRD's satisfaction is going to cost both money and your time under the best of circumstances. Remember that you are
always guilty of owing tax until you prove otherwise. It's not like a Freezone company in the Middle East or IBC in other jurisdictions where incorporating the right way equals zero tax for life. While simply paying the tax for a year or two may be cheaper than all of the compliance hoops you have to go through to get out of it, you run the risk of getting hit extra hard when trying to claim you don't owe tax later. In addition to proving you don't owe tax now they may demand that you prove how your operation is materially different from when you paid the taxes you technically didn't owe. You'll beat it, eventually, but all of this is a further time and money suck. Every year there are more fees and compliance hoops (auditing of all accounts is both a hassle and surprisingly high expense relative to the value provided rarely mentioned by people that have never owned a HK company) that must be completed perfectly, even if you will never actually owe tax. The red tape has been strongly moving in the wrong direction for the last 7-10 years and shows no signs of easing up when everyone eligible to run for public office is hand-picked by the CCP. In the current year
Singapore offers everything you would like about
Hong Kong with fewer headaches and no risk of your structure being made obsolete by communists determined to transform Hong Kong into a crappier version of Shenzhen. If you believe polls 80% of Hong Kongers want to leave...that's never a good sign. Getting a
bank account at a decent Singaporean bank isn't a cake walk anymore and will require a trip to Singapore (awesome city, make a vacation out of it) but it's nothing compared to trying to get an account in HK with less than $HK10m.
As a German citizen the US is a reasonably good offshore choice, but both state and federal tax codes are complicated enough that you do not want to do this yourself based on a few things you read on the internet. Find a decent lawyer in the state you will incorporate to set everything up properly. The US is one of those jurisdictions that can be great to you if you set everything up right the first time and an absolute nightmare if the slightest thing is wrong. If you screw up your structure they can and will nail you to the wall on a technicality. As a foreigner they'll probably be more interested in ripping you off than sending you to minimum security prison, but still not something you want. Delaware and Wyoming are common choices to incorporate, but Nevada, Florida, Texas and South Dakota offer zero corporate tax without the scummy feeling a Wilmington, DE mailing address could potentially give some of your clients. The prestige of having a Las Vegas, NV address may outweigh whatever the difference is for your business in one of those other states. Las Vegas is the new Times Square both for prestige and the quality of business done there. It's also one of the few major cities that is nicer today than it was 10 or 20 years ago. Something to consider.