from_eu_with_love 🏳️‍🌈🇪🇺

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@marcioemc_ A proposta não é sobre deixar de emitir vistos ao chegar aos 10M? Ou seja, fechar as portas a toda a gente em vez de tirar pessoas de lá?

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@BillyReinhardt @rodimusprime You almost got it right 😁

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@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.

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@MimoCrypto17 @BoringBiz_ Yes, correct.

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@MimoCrypto17 @BoringBiz_ And what do you think it will happen to your plot of land when no one else has a job because of AI?

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@BurgessBoston @TruedawnFm Everyone is saying that since 2021/22.

Eventually will happen, but it does make a difference when is that really 😁

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@FThatShitImOut @TruedawnFm

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@tmfpretty @NickADobos Yes, and everyone knows the best way to save the IPO is to block the usage of it's latest product.

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@ak_1490 @hallerite The AI act is still a thing? Jisas 🤦‍♂️

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@ChaseBrowe32432 @scaling01 It probably will, but opens the precedent.

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@BuildAfter40 @KobeissiLetter By everyone you probably mean the ETFs

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@rubenhassid @ThierryBorgeat He said "building the internet"

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@vvv1vvvvvvv @moneyfetishist @Fabian_v4

[moneyfetishist @moneyfetishist]

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

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@ken100bands @byalexai @kimmonismus Or update claude code to latest version.

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@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

[Pablo Espinosa San Mauro @pabloespinosa11]

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.

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@jl_zamith Agora "from memory" 😁

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

https://t.co/kDaI1z19ab

3 nos penalties, mas não importa

[from_eu_with_love 🏳️‍🌈🇪🇺 @noinputfound]

@MrnllMtt But even if the costs scale with the salary, it still pays off: if you get paid 3x more and spend 3x more, you'll save 3x more too.