Worldwide tax strategy and jurisdiction selection with substance and banking.

Client benefit

Concrete client benefits.

• The client avoids choosing a country only because of a headline tax rate.
• Residence, company, foundation and banking routes are compared together.
• German AStG, exit tax and reporting exposure are reviewed before moving assets.
• Substance and lifestyle constraints are made explicit.
• Kanzlei Meyers & Partner AG turns jurisdiction choice into an implementation plan.

Tax classification.

Low-tax planning must be checked against residence rules, exit tax, CFC, permanent establishment, reporting duties, anti-abuse law and local tax conditions.

• Zero-tax and territorial taxation limitations.
• Non-dom remittance and residence requirements.
• German sections 2, 6 and 15 AStG where relevant.
• CFC, place of management and permanent establishment risk.
• Banking, exchange of information and substance requirements.

Ongoing global administration.

The structure needs annual residence evidence, travel-day files, corporate substance, accounts, bank updates and cross-border reporting.

• Travel-day and residence file.
• Corporate substance and board documentation.
• Foreign accounts, CRS/FATCA and reporting checks.
• Annual review of law changes and family/business facts.

Set-up and implementation process.

• Define personal, business and family objectives.
• Compare candidate jurisdictions against tax, life and banking criteria.
• Review German and existing-country exit exposure.
• Design entity, foundation and banking route.
• Set transition calendar and annual compliance file.

Typical mistakes.

• Tax rates are compared without CFC and exit-tax review.
• Family life and centre of interests contradict claimed residence.
• Banking is not available for the chosen structure.
• Substance is too thin for company or foundation claims.
• Reporting duties are ignored across jurisdictions.

What Kanzlei Meyers & Partner AG delivers.

• Jurisdiction comparison matrix.
• Exit-tax, CFC and residence risk memo.
• Substance and banking feasibility file.
• Entity/foundation route map.
• Transition and document calendar.
• Annual global compliance checklist.

Documents for the first review.

• Current residence and travel pattern.
• Family, school and housing plans.
• Business model, clients and management location.
• Corporate and foundation chart.
• Asset and bank overview.
• Countries under consideration.

Result of the initial consultation.

The first review ends with a documented decision file: target structure, tax assumptions, exclusion points, implementation sequence, document list and clear next steps.

• Decision matrix with recommended structure and rejected alternatives.
• Tax and compliance workstream with open points, deadlines and responsible parties.
• Implementation plan for entity formation, banking, governance and ongoing administration.

Legal position and limits.

No jurisdiction is recommended on tax rate alone. Local advice, immigration, banking and all relevant foreign tax rules must be coordinated for the specific facts.

Frequently asked questions.

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