If German companies want to operate abroad, they have several possibilities for doing so. On the one hand, the entire business can be operated from within Germany, on the other hand, the establishment of a foreign subsidiary GmbH, a subsidiary partnership or a permanent establishment offers itself. A double taxation avoids the respective double taxation agreement or the national regulations. Decisive for the tax treatment is above all the legal form in which the foreign subsidiary or permanent establishment is operated. We give an overview of all three or four possibilities!
At its core, companies have four options to partially relocate their business abroad, in particular to serve foreign customers. In essence, these include:
This article does not replace tax or legal advice in an individual case. Facts, current law, jurisdiction, documentation and implementation remain decisive.