OVZA
New Horizons Paraguay
Ticker tape by TradingView

Digital Nomad Perpetual Traveler + Apartment in Cyprus = tax ?

Status
Not open for further replies.
There is no such DTA between Seychelles and Germany. If there‍ was, you would probably have to go live there in order to be eligible any⁠ benefits.

I think both give you problems. Seychelles a bit more as you probably won't even⁢ get good banking.

You first need to figure out how many weeks you want to︀ spend in Germany and then where you spend the rest. You can then let me︁ know for good adivce. But spending 5 months in Germany will only lead to the︂ advice to either leave completely or pay taxes there. You may not get caught, but︃ that is not part of an advice.
 
To cover most private relationship needs⁣ i would need to spend 3 months in germany (12-14 weeks).

Rest i would like⁢ to have somewhat of a base. As said Cyprus is attractive to me for that,︀ also from a quality of life and community standpoint. I can easily stay at that︁ base 5 months and the other 4 months i would travel around.

My money would︂ still be generated by my US LLC, so any structure that helps me get this︃ money in a favorible way why still offering as much protection to questions from german︄ authorities will be appreciated.
 
I think it might work then, in theory. But I⁠ doubt he wants to pay 15k in tax. And I also doubt that Malta will⁤ really defend him if he only has weak ties with them and barely pays any⁣ tax. They probably won't want to piss Germany off.

But thank you for sharing! I⁢ wasn't aware of the program, great to learn something new!
 
No, not really, like I explained. At least not with Cyprus.⁤
If they are too lazy to really look into you, yes. But then you could⁣ also just tell them that you live on the moon or a sailboat in Antarctica.⁢

Hahahaha!! You literally spoke to CY lawyers who told you you can just use a︂ Seychelles company and not pay tax in Cyprus! How is that a country with regular︃ taxation?
They were literally selling passports until a couple of years ago. Malta and Cyprus︄ are basically Carribean tax haven islands, just right in the center of the EU.
They are MASSIVE red flags to any other tax authority. Yes, they are EU members, so︅ yes, they will have to accept everything IF YOU REALLY LIVE THERE.
Telling them you︆ have moved to Cyprus will basically be like a big: "I HATE PAYING TAXES!! f**k︇ YOU!!!" to them.
Maybe they'll go "Ah, whatever", or maybe they'll go "Oh really? Cyprus,︈ huh? Let's take a closer look at this guy..."

But there's also a chance they︉ won't ask where you've moved - because it's not relevant for them.
Again, it all︊ depends on how much they want to check on you.
The only thing that is︋ relevant for them is that you are really GONE. But you won't be, and that's︌ your problem.

I didn't understand this.

This is pure magical thinking. "When they come for me... I'll pull out⁠ my magical paper and the German taxman will turn into dust!"
Do you really think⁤ they don't know there's a 60-day tax residency certificate in Cyprus?

There was a famous⁣ case with Lufthansa pilots some years ago who all declared that they had moved to⁢ Dubai or Thailand.
This is quite similar to your case - they surely also only︀ spent little time in Germany, they were pilots after all. Google it.

Tax is about︁ facts. Your center of vital interests will still be Germany if you spend up to︂ 5 months there. They won't care about your magical paper.
Your whole strategy is built︃ on the hope that they won't check you. And yet you still want to pay︄ tax in Cyprus.
 
Yes, if they find there is a PE. If he was ordinarily tax‍ resident in another EU country, then work as an employee of a foreign country would⁠ be protected under the tax treaty, Germany wouldn't be allowed to tax this.
But yes,⁤ there is a PE risk, especially if there are German clients.
 
You will not have protection under the treaty with⁤ such a setup, you would have to spend 183+ days in Cyprus for that.
Basically, your situation would be the same as if you had moved to a non-treaty country⁣ like the UAE.
So you'll just have to hope that the German tax office either⁢ doesn't investigate you, or that they come to the conclusion that you don't have habitual︀ abode in Germany.
Of course, staying 5 months in Cyprus and having an apartment there︁ is something that would help your case ("How could I have habitual abode in Germany︂ when I don't have an apartment there and I spend MORE time in my apartment︃ in Cyprus?!") - but it's not relevant. Since there is no treaty to protect you,︄ they only have to look at the time you spend in Germany.

I can't tell︅ you how high that risk is in practice, maybe 5 months in Cyprus, receipts from︆ Cyprus etc. are enough for them to back off. I think it's not impossible, could︇ even be likely.
But formally, there is no guarantee. Because if they say you are︈ still tax resident in Germany, the treaty won't apply to you.
 
How much money are we talking about by the way? You work as a freelancer?‌ How much do you even make per year?
 
No Germany clients, but if he is working from Germany, he probably would have to be⁤ hired as marketing guy or something to pay taxes while he is in Germany.
 
That's the wrong article. You have to look at the article for employment income -‌ and potentially the article for business profits.

Business Profits (Article 7):
The profits of an‍ enterprise of a Contracting State shall be taxable only in that State unless the enterprise⁠ carries on business in the other Contracting State through a permanent establishment situated therein.

Income from Employment (Article 14):
[...] remuneration derived by a resident of a Contracting State in⁤ respect of an employment exercised in the other Contracting State shall be taxable only in⁣ the first-mentioned State if:
a) the recipient is present in the other State for a⁢ period or periods not exceeding in the aggregate 183 days in any twelve month period︀ commencing or ending in the fiscal year concerned [...]

All EU-countries have such rules in︁ their treaties. Otherwise the bureaucracy would be crazy. Imagine a McKinsey consultant who works in︂ 10 different EU countries - is he supposed to file a tax return in each︃ of them?
 
Yes, and then, they just claim the income to be derived from a PE as‌ the guy has a room with good desk in his mother's house where he normally‍ works from.
 
Like I said, there is a PE risk, especially if there are German clients. Can't‌ say how big the risk is.
 
No German clients, he‍ could try it.

But it remains risky unless he can somehow justify the time spent⁠ there to be only for personal issues and not work.
 
I think at his income level just flying under the radar may‍ be best. Maybe, he can go live in Réunion and pay some small tax there⁠ while travelling.
 
The long term solution if you are willing to move is to basically obtain citizenship︁ or long term business visa in a 0 tax country. And once you have all︂ things fixed in place renounce your German citizenship. You can still get stuff you want︃ done in Germany through your family members or friends.
 
100k profit‍ 2024. Before that it was way less (below 30k). Not a freelancer, real online business.⁠

May i ask what your structure is?

What if i destroy the desk everytime i leave and then get a new one when⁢ i arrive? Jokes aside how would they ever know that?
How would they even know︀ i worked in the time being in germany? Business could be handled by freelancers abroad...︁

I have no german clients. Only outside EU clients.

What is "live in Reunion"
 
Sounds like you will have to pay exit‍ tax...
Just move to Bulgaria, pay 10%, done. Bulgaria is a Schengen country.

Not really comparable.

They don't have to know, they can just claim something, and︁ then it's up to you to prove them wrong.

Probably very little PE risk then.

He meant you can move to︃ the island of Reunion.
 
Status
Not open for further replies.

JohnnyDoe.is is an uncensored discussion forum
focused on free speech,
independent thinking, and controversial ideas.
Everyone is responsible for their own words.

Quick Navigation

Forums

User Menu

Login
Community platform by JohnnyDoe © 2025 JohnnyDoe
Top Bottom