Offshore Companies, International Tax Law

Posted June 30th, 2016 by Suzy

Establishment of companies in tax havens: questions of design strategies for incorporation in the Swiss offshore company formation: basically you must design strategies for offshore company gruendungen (tax havens, zero tax countries) in the context of starting new companies abroad between incorporations in the EU, DBA facts (State of residence of the foreign company has a double taxation agreement with the State of residence of the client or his firm) and non-DBA facts (offshore countries such as E.g. Seychelles, etc) are different. Generally, it is the most clients to assume that is the incorporation in a so-called zero tax shelter / non-DBA facts of the case (Seychelles, Belize, BVI, Panama etc.) adversely designed, compared to starting new companies in the EU or DBA facts. Tags are: adoption of design abuse (for German clients 42 AO), reversal of the burden of proof, negative effects German tax evasion control law (see also:) steuerhinterziehungsbk_gesetz.htm), g-20 agreement, German Foreign Tax Act (add-back taxation according to 8 Ftta: astg.htm) and the existence of a tax permanent establishment outside of the country defines itself through domestic law and not over 5 DBA (double taxation treaties), in the German law on the basis of 12 / 13 AO. “These negative effects can usually only be prevented if: the place of business overhead” detectable in its home country (E.g.

on the Seychelles, Belize, etc) book is: no nominee – or pure nominee director and Associate Director with employee contract between Director and society with normal/similar content and In the State a business established in a commercial manner (E.G. on the Seychelles, Belize, BVI) is installed (Office and rental contract) and an economic reason therefore incorporations are suitable for most clients in the EU, or at least the DBA facts better than companies in tax havens country renowned for. An exception is the UAE (United Arab Emirates, Dubai) in this context, since the UAE with many countries including Germany maintains a double taxation agreement (DTA) and knows no corporation tax or income tax.

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