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ExpertAdvisor01

281 karmajoined 11 tháng trước

Submissions

Germany's 'HS2' delayed for five years after engineering blunder

telegraph.co.uk
2 points·by ExpertAdvisor01·29 ngày trước·1 comments

German cabinet approves 3-month IP address retention

europeanconservative.com
13 points·by ExpertAdvisor01·3 tháng trước·3 comments

Third New Glenn launch suffers upper stage malfunction

spacenews.com
2 points·by ExpertAdvisor01·3 tháng trước·2 comments

comments

ExpertAdvisor01
·3 ngày trước·discuss
Platforms will stop offering E2EE . Didn't Instagram abandon E2EE ?
ExpertAdvisor01
·4 ngày trước·discuss
Has been implemented in mobas such as lol
ExpertAdvisor01
·8 ngày trước·discuss
I wouldn't say most.

It's around 55–60% of immigrants who come from Spanish-speaking countries.

Also, this uses official numbers, which reflect a larger Spanish speaking share than there is in reality (as people from Spanish-speaking countries have more straightforward visa processes).

So the real percentage is probably much lower (as there are a lot of undocumented migrants. 1.2 million applied for "legalization").
ExpertAdvisor01
·15 ngày trước·discuss
Because it's transparent so you pay income tax ( which is lower than corp+dividend taxes especially at lower incomes ) .

Later on when you scale, you can convert the LLP into an LTD.

Also you might avoid exit taxes as it is an partnership , if you move between countries.

Also there is basically no information in the post besides 2 founders in different countries.
ExpertAdvisor01
·15 ngày trước·discuss
Probably a UK limited liability partnership would be an option .

But you have to investigate how the Dutch will treat it .

You could apply for a advance tax ruling with the Dutch tax authorities before doing anything
ExpertAdvisor01
·16 ngày trước·discuss
The worst thing you could do as an us citizen (I assume ) and resident is to incorporate outside of the US.
ExpertAdvisor01
·16 ngày trước·discuss
You mostly use foundations for that purpose in civil law countries (which are also not part of the hague trust convention )
ExpertAdvisor01
·16 ngày trước·discuss
Useless + overhyped .

Company will end up as tax resident from the country where it is managed & controlled .

If there is an DTA the tie breaker rule applies and the country from where it is managed & controlled gets the right to tax .

Also you get to enjoy bureaucracy+ dual accounting in both countries .

If there is no DTA it can lead to double taxation .

And if you don't have a fixed place of management/business+ tax residency (basically nomading) a US LLC disregarded for tax purposes is a much better fit .
ExpertAdvisor01
·16 ngày trước·discuss
Estonia isn't 0% cit . Tax is just deferred until distribution.
ExpertAdvisor01
·16 ngày trước·discuss
What you describe is tax avoidance and not evasion.

Tax evasion is always illegal.
ExpertAdvisor01
·17 ngày trước·discuss
Unfortunately it doesn't work like that. You are just adding us bureaucracy+ dual accounting (euro/USD) to German bureaucracy where nothing changes .
ExpertAdvisor01
·17 ngày trước·discuss
You need to demonstrate real substance (such as actually managing/working from there e.g in your case Leipzig ) . If you can't prove real substance they will just shift it back to berlin and you could be also held liable for tax evasion (if there is a lower gewerbehebel )
ExpertAdvisor01
·17 ngày trước·discuss
Malta and Cyprus offer much better quality of life and also significantly less taxes .

Also Polands IP Box(5% tax rate) regime can be very interesting to software engineers right across the border.
ExpertAdvisor01
·17 ngày trước·discuss
If you don't like the laws/rules then just leave Germany . There is no justification for tax evasion .
ExpertAdvisor01
·17 ngày trước·discuss
What should the US LLC do ? It will end up being treated like a GMBH in Germany (keyword : Typenvergleich ) and you will have to do all the bureaucracy in the us + Germany and end up paying the same taxes
ExpertAdvisor01
·17 ngày trước·discuss
This will most likely result in Permanent establishment (PE) in Germany (e.g due to fixed place of business). That means Germany will tax the company anything which is attributable to the German guy.
ExpertAdvisor01
·17 ngày trước·discuss
Yes , but cfc rules are mostly targeted against passive income and exclude active companies. They wouldn't matter in that case anyway as he would shift the tax residency to Germany by managing & controlling the company from Germany.
ExpertAdvisor01
·17 ngày trước·discuss
Don't incorporate somewhere else it will only lead to disaster. The company will end up being German tax resident anyways due to management and control being in Germany as you live in Germany .

Then you have to be compliant in 2 jurisdictions (file forms/balance sheets in both countries etc..) and worst case you could become subject to double taxation (if there is no agreement).

The optimal solution is just to leave Germany .
ExpertAdvisor01
·17 ngày trước·discuss
Another recent example : https://www.telegraph.co.uk/world-news/2026/06/10/germanys-h...

They laid 600+km of cables wrong ultimately delaying the project by 6 years.
ExpertAdvisor01
·17 ngày trước·discuss
If they are still a German tax resident , they are committing tax evasion . § 1 Abs. 1 KStG