ExpertAdvisor01

I think it would be helpful for people in this thread to understand the differences between EU Regulations and Directives :

• EU Regulation: A binding legal act that applies immediately and identically in all EU countries as soon as it takes effect, without needing national laws.

• EU Directive: A legislative act that sets a mandatory goal that all EU countries must achieve, but allows each nation to pass its own laws to implement it.

It takes time for directives to take effect, unless a member state's national law already implements them.

Because it is an EU-DIRECTIVE.

Directives are not the same as regulations .

Directives are goals that must be achieved by adapting existing national laws or introducing new ones, and that takes time.

It was already decided in 1998 to phase out nuclear power under the SPD–Green coalition. They passed the Nuclear Exit Law in 2002.

It’s mostly the Green Party’s fault, as they have been vehemently anti-nuclear since their inception(1970s).

They had an emi license before .

It was only removed for a few hours . It is back up again

https://www.forbes.com/sites/siladityaray/2026/08/04/telegra...

Reason : https://www.forbes.com/sites/siladityaray/2026/08/04/telegra...

Telegram was removed from apps store. Reason currently unknown

Platforms will stop offering E2EE . Didn't Instagram abandon E2EE ?

Has been implemented in mobas such as lol

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").

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.

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

The worst thing you could do as an us citizen (I assume ) and resident is to incorporate outside of the US.

You mostly use foundations for that purpose in civil law countries (which are also not part of the hague trust convention )

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 .

Estonia isn't 0% cit . Tax is just deferred until distribution.

What you describe is tax avoidance and not evasion.

Tax evasion is always illegal.

Unfortunately it doesn't work like that. You are just adding us bureaucracy+ dual accounting (euro/USD) to German bureaucracy where nothing changes .

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 )

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.

If you don't like the laws/rules then just leave Germany . There is no justification for tax evasion .

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

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.

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.

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 .

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.

If they are still a German tax resident , they are committing tax evasion . § 1 Abs. 1 KStG

You still have to go to a notary and do paperwork to change the name of the company.

I think you misunderstood double taxation . You probably understood it as taxation on corporate and personal level. But in this context it means taxation in two jurisdiction (Estonia,Germany)

In Germany you need a notary in the us you don't.