GUHRSteuerberatung

Sparringspartner für Unternehmer.

Service · International tax

Relocation, IP structures and double taxation – cleanly solved.

Anyone moving GmbH shares to Dubai, Cyprus or Switzerland will meet §6 AStG – or be ambushed by it. We plan relocation, IP structures, transfer pricing and treaty application so the immediate taxation never triggers and BEPS does not become a trap.

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  • Nexus substance built in
  • CFC rules pre-tested
  • Treaty-proof design
up to 27%exit tax minimised through timing
6Structures in this area

Structuring catalogue

What we actually build for you.

Every card represents a real structure we implement for comparable mandates. Green is the upside, red is the pitfall – so you see where the lever sits and what we need to safeguard.

P67Highly complex

Exit tax on GmbH shares (§6 AStG)

For whom: GmbH directors planning to relocate

Upside

Defer or avoid tax on unrealised gains

Pitfalls
  • Immediate taxation of hidden reserves
  • EU deferral vs. third-country rules
  • 7-year lock-up
P13Highly complex

Exit tax planning (§6 AStG)

For whom: Emigrants with > 1% GmbH stake

Upside

Minimise up to €500k of exit tax through timing

Pitfalls
  • Extended limited tax liability for 10 years
  • Sham-residence risk
  • Common Reporting Standard exposure
P42Highly complex

IP box / licensing structure (abroad)

For whom: Tech/IT/SaaS GmbHs with proprietary IP

Upside

Effective tax on IP income of 2.5–9% instead of 30%

Pitfalls
  • Nexus substance requirements
  • CFC rules under §7 AStG
  • BEPS exposure
P65Highly complex

Transfer pricing

For whom: GmbHs with foreign subsidiaries / stakes

Upside

Shift profits legally to lower-tax jurisdictions

Pitfalls
  • Documentation duty under §90 (3) AO
  • Penalty surcharge
  • Permanent-establishment risk
P24Highly complex

Tax-treaty optimisation

For whom: Directors with cross-border activity

Upside

Avoid double taxation, reduce withholding

Pitfalls
  • Exemption vs. credit method
  • Activity clauses
  • Treaty-abuse rules under §50d EStG
P98Highly complex

Severance with cross-border element

For whom: Directors relocating abroad

Upside

~€9,350 saved via treaty allocation

Pitfalls
  • Source-state vs. activity-state principle
  • Residence-change timing
  • Treaty gaps
Which of these fits your situation?In a 30-minute strategy call we map your situation onto the catalogue and name the two or three structures with the biggest effect for you.
Book the strategy callFees & terms→030 555 721 370