What’s the best offshore setup for German resident planning eventual relocation, but paying taxes meanwhile?
- Thread starter anceps
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A simple Cyprus setup could help you a long way down the road, you don't need any advanced solution. Just make sure you use nominees and protect your UBO for as long as it take you to move out of germany.
Another good thing to do is to jump around before the final place you settle. have wrote a little about it inside mentor group back in time.
Another good thing to do is to jump around before the final place you settle. have wrote a little about it inside mentor group back in time.
From what you’ve described, this is exactly the type of situation where an offshore company formation makes sense. You clearly want something that’s compliant with German rules in the short term, but also flexible enough to keep using after you relocate and fully exit the German tax system.
Germany definitely complicates things, especially if you want to use profits from the company while you’re still resident there. That’s where the right structure becomes important.
One option that could work well is to establish a Marshall Islands company with bearer shares. The benefit of bearer shares is flexibility, they can be assigned to you or to someone else without having to constantly amend the corporate registry. Alongside that, you could︀ set up a second company, for example in Antigua and Barbuda, which would act︁ as the service provider to the Marshall Islands entity.
In practice, that would let you︂ control how much income flows to the Antigua company. You could then draw dividends from︃ Antigua, declare them properly in Germany, and pay tax as needed while you’re still there.︄ Meanwhile, the main profit-holding company (Marshall Islands) would stay neutral, ready for the long term,︅ and you’d have the freedom to adjust the structure when you relocate abroad.
This way,︆ you’re compliant in the present but also building a framework that’s sustainable once you’re out︇ of the German tax net.
Germany definitely complicates things, especially if you want to use profits from the company while you’re still resident there. That’s where the right structure becomes important.
One option that could work well is to establish a Marshall Islands company with bearer shares. The benefit of bearer shares is flexibility, they can be assigned to you or to someone else without having to constantly amend the corporate registry. Alongside that, you could︀ set up a second company, for example in Antigua and Barbuda, which would act︁ as the service provider to the Marshall Islands entity.
In practice, that would let you︂ control how much income flows to the Antigua company. You could then draw dividends from︃ Antigua, declare them properly in Germany, and pay tax as needed while you’re still there.︄ Meanwhile, the main profit-holding company (Marshall Islands) would stay neutral, ready for the long term,︅ and you’d have the freedom to adjust the structure when you relocate abroad.
This way,︆ you’re compliant in the present but also building a framework that’s sustainable once you’re out︇ of the German tax net.
Yes, the whole situation in Germany is not so easy once your income grows and you would like to relocate. If you operate as a sole trader, freelancer or without a company, it is good to leave Germany while your profits are low. In this case, the Entstrickungssteuer could be minimised depending on the calculation. If you're trying to leave Germany while your income is high, this could result in a higher tax, depending on how the Finanzamt would evaluate it according to the Entstrickungssteuer.︀
If you live in Germany and you would like to open a foreign company, there︁ is an obligation to report it. With the Wegzugsbesteuerung (Exit Tax) for companies, it will︂ also be considered if you had unlimited tax liability in Germany for 7 years within︃ 12 years. In 2025, they also added that there is now an exit tax for︄ shares in investment funds (500,000 euros and above).
https://www.grantthornton.de/en/insights/2024/extinction-of-exit-taxation-introduced/
While the limit might be 500,000︅ euros for the moment, who knows how soon it will be reduced.
The best advice︆ is clearly to leave Germany while you still don't earn much and relocate to a︇ better location with lower taxation. It is always better to start your business and company︈ outside Germany.
If you live in Germany and you would like to open a foreign company, there︁ is an obligation to report it. With the Wegzugsbesteuerung (Exit Tax) for companies, it will︂ also be considered if you had unlimited tax liability in Germany for 7 years within︃ 12 years. In 2025, they also added that there is now an exit tax for︄ shares in investment funds (500,000 euros and above).
https://www.grantthornton.de/en/insights/2024/extinction-of-exit-taxation-introduced/
While the limit might be 500,000︅ euros for the moment, who knows how soon it will be reduced.
The best advice︆ is clearly to leave Germany while you still don't earn much and relocate to a︇ better location with lower taxation. It is always better to start your business and company︈ outside Germany.
Yes, it can work depending on the situation. I did this about 4 years ago, also involving Germany, but I came from another country and relocated there for 2 years while being employed in Switzerland through my own company, working in Germany, never had the slightest issue.
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