Optimize tax for high income self-employed software dev in Austria

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domperignon

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Dec 26, 2022
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Hi,

What options do I have for tax optimizations living in Vienna, Austria?

Income from‌ freelance software development ~$400,00K / year
 
Leaving Austria would probably be the easiest option

If I am not‌ mistaken, a Cyprus construct would work well.
Operative Limited will be operated by a Cypriot‍ partnership.
Limited partner would be you, general partner would be the limited company
 
Not in his case since he is the developer and work is performed in‍ Austria.

However the thing that make the Cyprus contruct work is paragraph 8 of article⁠ 7 of the DTT between Cyprus and Austria that says "(8) The term "profits"⁤ as used in this Article shall include profits of a partner from his participation in⁣ a partnership, including participation in a a silent partnership."

If you look at the⁢ DTT between Cyprus and Hungary you'll see that there's paragraph 6 of article 7 that︀ says "(6) The provisions of this Article shall also apply to shares in profits︁ arising from participation as a silent partner in an enterprise."

OP should seek professional︂ tax advice but that line could mean that if he goes and form a company︃ in which he is only an investor and job is performed through a permanent establishment︄ in Hungary, he could potentially pay only 9% CIT in Hungary and then as per︅ paragraph 6 "shares in profits arising from participation as a silent partner in an︆ enterprise" should be tax free but i'm 100% speculating.

Obviosly OP should hire somebody in︇ HU and rent an office BUT he potentially could commute to Sopron which is one︈ hour drive from Wien, cross the border without anybody knowing and perform the work himself︉ alongside the employee.
 
This is the guy who came up with the Cyprus structure so a‌ consultation with him will surely help you shed light on this matter. Let us know‍ how it goes!
 
Thank you, I will reach out.

Are there any⁠ other optimizations that are better than just having it as personal income?
 
Easy, do‌ not file any tax return, get paid by cash and put it under your mattress‍
 
the video is about the fact that if you move‌ abroad from Germany and then come back after a few years with the sole proprietorship,‍ that you can write it off over the years.

Nevertheless, during the time abroad, the⁠ entrepreneur must pay tax on his profit in the respective country where he is located⁤ for the years.
 
Habibi, come to Dubai!
Here you'll pay 0% tax and you can keep all the‌ money you make.

I'n most parts of Europe you'll give to the government at least‍ 25%.
So that's money wasted and you get basically nothing in return and in your⁠ case that's minimum 100k/year.

In here you can keep those 100k/year use that money to⁤ rent a nice apartment or home, buy a car, eat well etc.
And the best⁣ part - you don't have to even think about filing for tax.
 
Its easy work with‍ a third party company like a seychelles ibc to accept the money(payments through their invoice)⁠ and ask them to send you crypto for a percentage - you are sorted mate.⁤ If you need any further help let know. No need to move anywhere and complete⁣ peace of mind.
 
With that kind of‍ money why not just try and move to Switzerland? Seems like path of least pain.⁠ Half a year in Schweiz, half a year in Austria.
 
Any updated info or new experiences about this mixed Austria (residence) + HU company (with‌ PE) setup?
 
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