Zero-PIT regimes
The absence of personal income tax may be attractive but does not remove exit tax, CFC or effective-management questions.
Global Tax Analysis
Target countries must be reviewed from the departure-country perspective, not only by local tax rates.
A low personal tax rate does not by itself make a relocation robust. For German-linked entrepreneurs, exit tax, extended limited taxation, CFC rules, place of effective management, CRS, substance and defensive tax rules must be considered together.
Country assessment logic
Territorial regimes
Foreign-source income rules must be tested against the source country and the structure documents.
Special regimes
Special tax regimes may have conditions, deadlines, reporting duties and anti-abuse limits.
High-substance locations
A higher local tax cost may sometimes produce a clearer governance and banking position.
German-linked review points
- Exit taxation on shareholdings and potential deferral conditions.
- Extended limited tax liability and continuing domestic economic interests.
- CFC risks, passive income, substance and effective management.
- CRS/FATCA reporting, banking story and source-of-funds evidence.
- Defensive tax rules and treaty access where relevant.
Output
- Tax-country matrix comparing personal, corporate, foundation, banking and reporting effects.
- Relocation sequence with steps before and after moving.
- Open professional review points for departure and destination country.
- Document list for residence, bankability and governance.