@MimoCrypto17@BoringBiz_ If the society collapses, having a plot of land is not as beneficial as it is right now, with a functional society.
That's why i don't understand why would it be so beneficial.
If you fall for this "Germany wanted 55 percent so I moved to Paraguay and now I pay zero" shit you deserve the Betriebsprüfung that is coming for you
No one who has actually structured real wealth talks about it this way
No one running a real Familienstiftung is posting about it
No one with a serious Steuerberater is announcing the structure on Twitter
The entire post is slop
I am not a tax advisor (so take my words with cautions and maybe @bowtiedbrazil can call out when I say something wrong)
I have one and I pay him well
What I am is someone who has actually insights of real German structures and hear a lot stuff of people get destroyed for exactly the kind of advice this post is selling
So let me walk through why everything in it is wrong
Start with the math
1.2 million euro revenue is not 1.2 million euro of personal tax exposure
The founder pays Körperschaftsteuer plus Gewerbesteuer plus Solidaritätszuschlag at the company level which lands around 30 percent on profit not revenue
He then pays personal income tax only on what he actually distributes to himself
If he was paying 660 thousand euro of personal tax on this business he was either drawing the entire revenue as salary which no German founder does because the structure is moronic, or you do not understand the difference between revenue and taxable income
Either way the 55 percent number is the kind of figure that sounds correct to people who have never seen a German tax return
Anyone who has actually run a GmbH knows the effective combined rate on retained earnings is closer to 30 percent and on distributed dividends is closer to 47 percent after Teileinkünfteverfahren
The 55 percent on 1.2 million headline is the first tell that the author is selling a fantasy to people who do not know the numbers
Now to the structure
US LLC for operations
The German Finanzamt does not care that the LLC is in Delaware
If the founder is tax resident in Germany the LLC profits are attributed back to him under the Außensteuergesetz Hinzurechnungsbesteuerung if the LLC is passive
If the LLC is active and he is managing it from Germany he has just created a German tax-resident permanent establishment for the LLC because management substance follows the founder
He has not avoided German tax
He has created an additional German tax filing obligation in a foreign legal wrapper
Panama company for IP holding
Panama is on every relevant grey list and several black lists depending on the year
Royalty payments from a German operating entity to a Panamanian IP holding company trigger automatic disallowance of the deduction under the Lizenzschranke since 2018
The German tax code specifically targets exactly this structure
The author either does not know the Lizenzschranke exists or is hoping the reader does not
Panama foundation for asset protection
Panamanian foundations are reportable under CRS
Germany has full information exchange with Panama since 2018
The Finanzamt sees the foundation the same year it is created
Asset protection through a Panamanian foundation while remaining tax resident in Germany is reportable as a controlled foreign structure under paragraph 138 AO
Failure to report is a separate criminal offense beyond the underlying tax fraud
Paraguay tax residency
This is where the fantasy completely falls apart
You do not become a non-resident of Germany by filing paperwork in Paraguay
You become a non-resident of Germany by physically leaving Germany and severing your center of life
That means giving up your German apartment, deregistering at the Einwohnermeldeamt, moving your family if you have one, moving your bank accounts, moving your phone number, moving the operational substance of the business, and spending fewer than 183 days per year in Germany
A founder running a 1.2 million euro German ecommerce business is generating revenue from German customers, fulfilling from German warehouses or German fulfillment partners, advertising on German platforms, and dealing with German suppliers
His center of life and the business's center of management are both in Germany regardless of what stamp Paraguay put in his passport
The German Finanzamt does not recognize a paper residency in Paraguay when the actual life and business operations remain in Germany
This is called Scheinwohnsitz and it is the most common attack vector the Finanzamt uses on people who try exactly this structure
The penalty is back taxes plus interest plus a fine plus potential criminal liability under paragraph 370 AO for Steuerhinterziehung
The author claims the tax bill went from 660 thousand to zero
What actually happens when this structure gets reviewed and it will get reviewed because the German Finanzamt has been specifically targeting this exact pattern for the last six years
The founder gets a Betriebsprüfung
The Betriebsprüfung discovers that the German operating substance never left Germany
The Finanzamt reassesses six years of back taxes at full German rates
They add Hinterziehungszinsen at 6 percent per year on the unpaid amount
They add a fine that scales with the severity of the evasion
They refer the case to the Staatsanwaltschaft for criminal proceedings
The founder is now paying 660 thousand euro of original tax plus six years of interest plus penalties plus criminal defense costs and potentially serving a sentence
The accountant the author claims called him to ask how the structure works did not call him
The accountant in the story is a fictional device
Real German Steuerberater do not call random Twitter accounts to ask how someone evaded 660 thousand euro of tax
Real German Steuerberater would refuse to sign the books for a structure like this because they would lose their license under paragraph 70 StBerG for participating in obvious tax evasion
The author then claims he sent the accountant an invoice
This is the giveaway
The entire post is a lead gen funnel for the author's own services
He is selling the dream of zero tax to founders who do not know enough to recognize that the structure he is describing is textbook Steuerhinterziehung wrapped in legitimate sounding entity names
The people who buy his service get the structure
The structure gets discovered within 3-5 years through CRS reporting or a Betriebsprüfung
The customer becomes the defendant
The author moves to the next country and posts the same thread with different entity names
This is the exact pattern that played out with hundreds of German YouTubers and dropshippers who set up Dubai entities in 2019-2021 and are now in active proceedings with the Finanzamt for back taxes plus criminal charges
The Cum Ex prosecutions taught the Finanzamt that aggressive structures can yield criminal convictions
They are no longer settling these cases quietly
They are prosecuting them as Steuerhinterziehung in besonders schwerem Fall which carries up to 10 years imprisonment
The author of this post is offering a fast track to that prosecution and charging the founder for the privilege
You can only legally pay less tax than your peers if you understand the German tax code at a depth most accountants do not reach
A real understanding of Außensteuergesetz, Lizenzschranke, paragraph 138 AO disclosure requirements, the Erbersatzsteuer cycle on Familienstiftungen, the 95 percent exemption inside a Holding GmbH
That is the definition of structural intelligence in this domain
Achieved only by going deep on the actual legal code and grasping it from first principles so you can build structures that survive a 6 year Betriebsprüfung and three generations of family succession
There is nothing admirable about a guy claiming he reduced 660 thousand euro of tax to zero by stamping his passport in Paraguay
People posting this nonsense are either dishonest and making the structure sound effortless so you will like them and buy whatever consultation package they are selling because the product cannot move without manipulating your perception of them
Or they are genuinely operating this structure and will be in active proceedings with the Finanzamt within five years which means they have not actually achieved anything that should warrant your attention
Either way you lose if you take the bait
@atmoio "In the peak of the crypto bubble we thought reality was going to be transformed into financial liberty and democratization for all"
We didn't. It was quite obvious it would not. No one could explain why it would.
That's the difference
Me sigue alucinando lo lejos que está comunicativamente la NBA de cualquier competición de fútbol. Mientras la Premier League está preocupada de borrar de Twitter repeticiones de goles y dificultándote el acceso al contenido, llega la NBA y te sube casi 4 minutos del final de uno de los partidos más importantes del año.
Jamás entenderé de dónde viene la creencia de que si le das a la gente parte del contenido gratis, van a dejar de pagar por el producto completo. Nadie va a dejar de pagar por la NBA por ver este vídeo, pero sí que alguno puede empezar a interesarse gracias a él.