Do you own and manage company in germany? If yes you are tax resident, if not you pay exit tax. Winwin.
This what ifs do not really work in tax laws. The question is, if your current current structure and tax law interpretation will hold in 8 years. After germany had new election, new socialist goverment changed and it is trying to milk everyone.
Some flight ticket from lufthanza are not going to save you!
Crazy theory: most posts here are from German Tax office. They give a "free" advice, and send a fat tax penalty 5 years latter! Suprise: you never left!
> be in Germany twice a year to sign off on having done the management within Germany.
Pretty stupid. You are signing paper that claims you never left Germany!!!
You are opening up yourself to personal German tax residency, with all pleasures it brings. Payable 10 years back!
And do not believe that 185 days bs. Correctly losing tax residency in state like Germany, Denmark, Norway or Australia is very difficult. You can not keep any assets like company or house there!
Edit: why downvotes? Many states only require 90 days or less to become tax resident. Australia is fine with a house. Norway will tax your income for 3 years after leaving!
Claiming you manage holding company within Germany, is a huge red flag!!!
But maybe I read wrong history books.