Parent-subsidiary directive: 0% GmbH withholding tax thanks to EU holding company? 

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Is it possible to avoid the 25% withholding tax due in Germany on the profit distribution (dividend) of a GmbH if the GmbH shareholder lives abroad? Couldn't the shareholder simply set up a holding company, e.g. in Cyprus or Malta, to which the GmbH is transferred and then collect the dividends in Cyprus without deduction in accordance with the EU Parent-Subsidiary Directive?
In various forums or on relevant “expert” websites, you often read a very clear “no” or people talk about possibilities and methods that fail in practice.
In this podcast, we talk very clearly and openly about what works and what doesn't work.
And there is another category of possibilities. Namely, ways that “don't make sense” or only work in theory. You know this from skat: “Jack trumps all”. And directives issued by the German tax office or the European Union to prevent tax avoidance within the EU - these now “override” a number of theoretical ways of simply avoiding GmbH withholding tax. Therefore, you should really only use a German GmbH from abroad if there are really compelling reasons to do so. And we also address this topic.
Tax expert Sebastian Sauerborn explains in the podcast how you can legally avoid or reduce withholding tax with a German GmbH and why a GmbH as a holding company could bring other advantages in some cases.
If you have any further questions, please write in the comments or arrange a consultation: www.auslandsunternehmen.com/b...
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= About Perspektive Ausland (perspective abroad) =
Anyone who wants to move as an entrepreneur or freelancer from German-speaking countries to (tax-efficient) foreign countries or become a digital nomad has a lot of tax and legal questions.
Country selection, international tax law, setting up a company abroad, exit tax, visas, capital investments and asset protection - these are just some of the topics that you now have to deal with.
Perspektive Ausland (perspective abroad) is a German podcast from London that deals with exactly such questions. No matter what your motivation for moving abroad is - less taxes, more freedom or a higher quality of life - you've come to the right place.