Low tax entity/foreign earnings

[bobo60]

I need to regularise my tax affairs. I am aware the final outcome will depend on a consultation with a tax expert; any initial advice will be to aid preparation and change to the business model.My current status is as follows:
(1)I am a New Zealand citizen and do not stay in any one country for more than 3-6 months.
(2)My current operating base is in Germany where my products are sourced/exported and tax appropriately
(3)Additional income are from:
(a)royalties from my books
(b)seminars/courses run worldwide and sale of
related products
(c)building consultation work
My current thinking is to set up a company in a low tax based country to minimise taxes payable myself and my customers and to satisfy any local compliance issues. Many thanks for any advice and recommendations.

[hvasilis@cytanet.com]

Hi,

The basic idea is to transfer the assets that generate the income to a company registered in a low tax jurisdiction and if it is tax efficient to change your personal tax residency status as well.

There are several issues that needed to be resolved first:
a) it may not possible to do that for all types of incomes. It will depend on the nature of the income and how and where it is generated.
b) the tax effect of transferring assets/business and the way to do that.
c) whether it is necessary to change personal tax jurisdiction.
d) whether a holding company is also needed to accumulate income from other companies and distribute it to you

There is no straightforward answer without more information about the size of each income type and jurisdiction involved.

If you want a summary tax plan please send me answers to the following questions:


(1) You are a tax-resident of which country?

(2) what is the expected annual size of income from the following sources in Euro:
a) sale of products
b) royalties of books
c) seminar /courses
d) consultation work

(3) what is the total tax burden on that expected income

(4) Are any companies currently used to channel the income you or not? if yes, in what jurisdictions are they registered and taxed?

3) Is all income taxed only in Germany?

4) Are your products manufactured in Germany?

5) seminar/ courses are delivered by yourself or by employees?

6) is building consultation work provided on site or from a distance?

7) where are your customers located?


It is a complicate situation involving income taxes, capital taxes and VAT issues therefore more information is needed


Regards,
Vasilis Hadjievangelou

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Vasilis Hadjievangelou, FCCA, BA (Hons)
Certified Public Accountant - Cyprus
198 Makarios avenue, Marinos Court, 2nd floor, flat 21, 3030 Limassol, Cyprus
P.O.Box 53288, 3300 Limassol, Cyprus
Tel:+357-25-340-176
Fax:+357-25-341-208
Email:hvasilis@cytanet.com.cy
Internet:http://www.geocities.com/hadjievangelou/
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