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Comment by Loic | Hacker News Reader

Take a good lawyer, accountant. I am French and created two companies in UK (Ltd) and one in Germany (GmbH). In theory, UK was better, in practice, because I live in Germany, the GmbH is more convenient. Also, a lot of your optimisations are dependent on your products. Are you selling software (licenses), consulting or goods? Are you doing import from outside of the EU? Sometimes, depending on your product, a country which is normally not "interesting" turns out to be a great place if you setup more than one company and split who is getting the money for what (here I have software licensing and development in mind).

At the end you need the details to be able to find the good answer, because for taxes, it is always a question of details.

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How do you handle the tax authorities in Germany then:

If you are resident in Germany and you are the main business decision maker in the UK company, German tax authorities would ask to tax you pay corporation tax for the Ltd. in Germany which can complicate things (I am not talking about your personal income tax).

Is this not a big mess or how should one deal with this? Do you frequently travel to UK to do 'main business decisions' there?

Great thread btw

Interesting. What are your obligations in Germany when you have a UK Ltd? How much of a hit do you get on your personal taxes? I've heard of someone with a Ltd operating completely under German tax law, but that sounds like a nightmare.

This is why now I am fully based in Germany and closed my company in UK. It started to be a nightmare. I started the company in UK before being in Germany, I kept it will being in Germany, but as basically a "one man Ltd" the Germans started to make problems (basically behaving like I tried to wash/hide money). Also, having the company now in Germany I was able to shift more expenses on the back of the GmbH, so you get some benefits there.

This is why, the best option is to take a good accountant, you really have no "magic formula". If someone is selling you "package" for a flat fee, you are nearly sure to have problems down the line. Even in good faith, when the tax authorities start to attack you because they consider that they think that maybe you did something wrong, they can make your life a nightmare and this totally legally.

So, handle everything with care, take a good accountant/lawyer and document everything.

I almost missed your reply, I might end up taking a similar road so thank you for your advise.

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