In times of constantly changing tax parameters and rising taxes and duties, the German tax structure is more and more perceived as disadvantageous. In searching for
– solutions to avoid domestic taxation, company owners not only move production sites out of the country, but also transfer their residence to a foreign country with lower taxes. There is an increasing demand for a comprehensive analysis which can, however, only be made properly on a country-to-country basis. Any transfer of residence must be regarded as an extraordinary and complex instrument of international tax management requiring the involvement of different legal and taxation systems. This book aims at examining the possibilities of international tax management by transfer of residence. From the German point of view,
transfer of residence also includes the planned avoidance or reduction of German taxes. The author presents the aspects of tax management relevant to transferring residence from Germany to Austria, respectively from Germany to the Slovakian Republic.
Frankfurt am Main, Berlin, Bern, Bruxelles, New York, Oxford, Wien, 2006. 135 pp.
Contents: Comparison of Income Tax System and Tax Burden in Germany, Austria and Slovakia – Tax-Affecting Transfer
of Residence – Abandonment of Residence in Germany – Double Taxation Treaty Germany-Austria and Germany-Slovakia – Allocation
of Rights in Accordance with Limited Tax Liability and Double Taxation Treaty – Extended Limited Tax Liability of sec. 2 German
Foreign Tax Relations Act – Expatriation Taxation of sec. 6 German Foreign Tax Relations Act – European Legal Standpoints.