Digital Nomad Perpetual Traveler + Apartment in Cyprus = tax ?

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daniels27 said:
I mean was anybody here ever involved in deregistering in Germany and then travelling around the world and being questioned by the authorities about their ending of tax liabilities?
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A guy I know moved to Portugal and they wanted to see proof that he had really been out of the country for 182+ days the following year (receipts etc.). As far as I know, after that, they didn't bother him anymore.
 
How is Germany if you move back after 3 years, can they consider you tax resident for the whole eriod you were away, if you weren't tax resident anywhere else during that time?
 
Xshore said:
How is Germany if you move back after 3 years, can they consider you tax resident for the whole eriod you were away, if you weren't tax resident anywhere else during that time?
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I'm not an expert, but I believe so, yes. They can say you didn't really leave, you only went on an extended vacation.
 
JustAnotherNomad said:
But you can only have true peace of mind if you spend 183+ days in Cyprus, and then you won't need the company.
But in that case, Cyprus could also tax your US LLC. Will they do that? No idea. But there's a good chance they could at least in theory see it as a Cypriot corporation, so you'd have to pay for an audit etc.
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In this case (not needing a company point you made), wouldn't Cyprus authorities see the US LLC as personal income and tax it at the full personal rate of 35% - since its a pass through entity and not a corporation?
 
Leo Vanguard said:
In this case (not needing a company point you made), wouldn't Cyprus authorities see the US LLC as personal income and tax it at the full personal rate of 35% - since its a pass through entity and not a corporation?
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This has been discussed in different places, for example:

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Thread 'US LLC + Cyprus residency'

Mar 25, 2020
Does anyone have experience with US LLCs (disregarded entities) and Cyprus residency? (I assume the LLC would have to be owned by a Cypriot company for this to work.)
Or is there a catch?

Also in this thread, see comments by @Radko :

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Post in thread 'Digital Nomad Perpetual Traveler + Apartment in Cyprus = tax ?'

Jan 24, 2025
Radko said:
In Cyprus, a U.S. LLC is generally treated as a pass-through entity for tax purposes, meaning that its income is not taxed at the entity level but is reported on the personal tax returns of its members.
The LLC's income is taxed at the owner's personal income tax rate in Cyprus, which can be as high as 35%, depending on earnings
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Are you sure? Isn't that a contradiction to what you have written below?
I also believe I have heard people say otherwise, but maybe they were misinformed or trying to sell something.

Radko said:
However, if the LLC is deemed a tax resident of Cyprus due...
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It seems very clear to me that the income is taxable in Cyprus, either as corporate or personal income.
But Cyprus probably doesn't really enforce this.

Just because the entity is viewed as transparent by the US, it does not mean that the other country cannot view it as a corporation (opaque).
 
Citizen of the world's most aggressive tax state thinks he can be a perpetual traveler and avoid taxes by living in hotels, hilarious. This is not going to work at all.
 
10101 said:
Citizen of the world's most aggressive tax state thinks he can be a perpetual traveler and avoid taxes by living in hotels, hilarious. This is not going to work at all.
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It absolutely works. There is case law for people leaving to live on a sailboat. They are not taxable.
The issue with OP is that he wants to still spend significant time in Germany.
 
JustAnotherNomad said:
It absolutely works. There is case law for people leaving to live on a sailboat. They are not taxable.
The issue with OP is that he wants to still spend significant time in Germany.
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It works until the day when the german tax authorities investigate you and if you can't proof that you're tax resident somewhere else you're charged with tax fraud. Even if you've broken up all connections to germany.
 
10101 said:
It works until the day when the german tax authorities investigate you and if you can't proof that you're tax resident somewhere else you're charged with tax fraud. Even if you've broken up all connections to germany.
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Yawn. Show me the law or get out of here.
 
JustAnotherNomad said:
Yawn. Show me the law or get out of here.
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You have no idea lol. It's the standard tax law that calls it center of interest. It's always germany until you get new residency.

Individuals who claim to no longer be tax residents, German tax authorities may still consider them as tax residents if they cannot prove that they have established tax residency in another country. Without such proof, the authorities can assume that their "center of vital interests" remains in Germany, which keeps them under Germany's tax jurisdiction.
 
10101 said:
You have no idea lol. It's the standard tax law that calls it center of interest. It's always germany until you get new residency.
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Show me the tax law. Hint: Germany does not even have center of interests in its tax residency rules.

10101 said:
Individuals who claim to no longer be tax residents, German tax authorities may still consider them as tax residents if they cannot prove that they have established tax residency in another country. Without such proof, the authorities can assume that their "center of vital interests" remains in Germany, which keeps them under Germany's tax jurisdiction.
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Show me the law or stop talking out of your behind.
 
The most perpetuated tax myths on the internet:

* You cannot be without a tax-residency. If you don't have a tax residency, you will be tax resident in your country of citizenship. (What about a child born to non-Emirati parents in the UAE and the parents permanently leave the UAE to live on a boat after the birth?)
My favorite part about is that they can never point to an applicable law, they refer to "the OECD" or random tax treaties, and they never even understand the sentences they are quoting.

* Tax residency certificates are magical papers that will make any tax inspector cry out in despair and turn into dust.

* You can set up a company in another country and only pay tax in your home country on the money you pay out from the company.

* You cannot be an employee of a company that is based in another country, they would have to set up a local company.

* You can avoid VAT by setting up a company in a country that has no VAT.

There's probably more, but these ones are really popular.
Whenever someone makes such a claim, you immediately know they have no idea what they are talking about.
 
JustAnotherNomad said:
Show me the tax law. Hint: Germany does not even have center of interests in its tax residency rules.



Show me the law or stop talking out of your behind.
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Germany does not explicitly state that a person must establish tax residency elsewhere after leaving, but failing to do so can trigger investigations and assumptions by tax authorities. German law assumes that individuals should have a tax residency somewhere, based on:
  • The principle of the "center of vital interests": If you have strong personal or economic ties to Germany (or lack ties elsewhere), authorities could argue your tax residency remains in Germany.
Key points where this assumption comes into play:
  • German Fiscal Code (Abgabenordnung) Section 90 AO: This section requires individuals to cooperate with the tax authorities and provide evidence (e.g., registration in a new country, residency permits, utility bills, etc.) to prove they no longer hold tax residency in Germany.
If you fail to provide this proof, German authorities may challenge the legitimacy of your "non-residency" and claim you owe taxes in Germany.

But it's not only that. They also bend the law however they want, especially in such cases. Can't show proof of new tax residency? tax fraud.
 
JustAnotherNomad said:
* You cannot be without a tax-residency. If you don't have a tax residency, you will be tax resident in your country of citizenship. (What about a child born to non-Emirati parents in the UAE and the parents permanently leave the UAE to live on a boat after the birth?)
My favorite part about is that they can never point to an applicable law, they refer to "the OECD" or random tax treaties, and they never even understand the sentences they are quoting.
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I remember that one. Do you believe it?
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Post in thread 'Best country for a freelancer / digital nomad post-covid'

Dec 17, 2024
NewHorizonsParaguay said:
If you do not meet the time and substance criteria in any country, the country of your citizenship is your tax residency.
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Very interesting. Which law regulates that?
 
10101 said:
Germany does not explicitly state that a person must establish tax residency elsewhere after leaving,
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Oh really.

10101 said:
but failing to do so can trigger investigations and assumptions by tax authorities.
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Sure, then you show them proof that you have cut your ties.

10101 said:
German law assumes that individuals should have a tax residency somewhere, based on:
  • The principle of the "center of vital interests": If you have strong personal or economic ties to Germany (or lack ties elsewhere), authorities could argue your tax residency remains in Germany.
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Show me the law.

10101 said:
Key points where this assumption comes into play:
  • German Fiscal Code (Abgabenordnung) Section 90 AO: This section requires individuals to cooperate with the tax authorities and provide evidence (e.g., registration in a new country, residency permits, utility bills, etc.) to prove they no longer hold tax residency in Germany.
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Sure, then you show them proof that you were not in Germany.
You have to be properly gone, obviously, you can't just go on vacation.

10101 said:
If you fail to provide this proof, German authorities may challenge the legitimacy of your "non-residency" and claim you owe taxes in Germany.
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Of course they can. They can say you still live in Germany, until you can prove that you do not.

10101 said:
But it's not only that. They also bend the law however they want, especially in such cases. Can't show proof of new tax residency? tax fraud.
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Nonsense. There are countries like Thailand that only consider you tax resident after 183 days per calendar year in the country.
You can rent an apartment in Thailand and spend 180 days there and if you travel to different countries (not Germany) the rest of the year, you cannot be tax resident in Thailand.
But you also cannot be tax resident in Germany.
Show your rental contract and utility bill to the German tax authorities and proof of your travels (flight tickets, receipts, credit card statements), and they have no case.
This is perfectly legal and well-established, same in the UK.
 
JustAnotherNomad said:
Oh really.



Sure, then you show them proof that you have cut your ties.



Show me the law.



Sure, then you show them proof that you were not in Germany.
You have to be properly gone, obviously, you can't just go on vacation.



Of course they can. They can say you still live in Germany, until you can prove that you do not.



Nonsense. There are countries like Thailand that only consider you tax resident after 183 days per calendar year in the country.
You can rent an apartment in Thailand and spend 180 days there and if you travel to different countries (not Germany) the rest of the year, you cannot be tax resident in Thailand.
But you also cannot be tax resident in Germany.
Show your rental contract and utility bill to the German tax authorities and proof of your travels (flight tickets, receipts, credit card statements), and they have no case.
This is perfectly legal and well-established, same in the UK.
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You're really funny! They want actual proof of tax residency, guess why you can apply for tax residence certificates in most countries? Do you think the Finanzamt, the world's most aggresive tax authority, cares about your longer Thailand holiday? You'd need to show them proof you are resident and pay taxes in Thailand. They don't care how much time you spend somewhere or where you holiday or whatever, they care where you are resident and where you pay taxes.
 
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