ITS - International Tax Structures

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• KGaA model alternatives?

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  Ralf Fehrensen    Premium Member

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  KGaA model alternatives?

  In the past a regularly used model to avoid a taxation of profit distributions from non German compnanies to German individuals was to interpose a non German company, which was held by a Geman KGaA, whereby the German individual was a so called Kommanditaktionär. Dividends paid to him were solely subject to a taxation with approx.1.5 - 2.0%
  However meanwhile the German ministry of finance plans to implement a new paragraph § 50c(11) German income tax law, whichregulates, that a dividend paid to a Kommanditaktionär qulaifies as a dividend subject to the regular taxation of individuals.
  Issue of the model were the implementation and running expenses, so that such model was interesting if the yearly tax savings were above 25KEURO.
  We are now looking for alternative structure.
  If someone knows a proper established model or has an idea for a new one I would be pleased if he contacts me.
  
  Ralf
  
  • 12 Feb 2012, 11:54 am
  Ralf Fehrensen wrote: > In the past a regularly used model to avoid a taxation of profit > distributions from non German compnanies to German individuals was to > interpose a non German company, which was held by a Geman KGaA, > whereby the German individual was a so called Kommanditaktionär. > Dividends paid to him were solely subject to a taxation with > approx.1.5 - 2.0% > However meanwhile the German ministry of finance plans to implement a > new paragraph § 50c(11) German income tax law, whichregulates, that a > dividend paid to a Kommanditaktionär qulaifies as a dividend subject > to the regular taxation of individuals. > Issue of the model were the implementation and running expenses, so > that such model was interesting if the yearly tax savings were above > 25KEURO. > We are now looking for alternative structure. > If someone knows a proper established model or has an idea for a new > one I would be pleased if he contacts me. > > Ralf