Exit tax and residence
Shareholdings, tax residence, return scenarios, deferral options, migration timing and documentation are reviewed before steps are taken.
International
International tax, exit tax and UAE structures reviewed as one system.
International structures need a coherent position on residence, place of management, substance, treaty access, CFC, exit tax and banking/KYC.
UAE companies: free zone, mainland, holding
Licence, UAE corporate tax, substance, place of management, bank account, UBO, accounting and international tax connections are reviewed together.
CFC and foreign company risks
Control, income classification, low taxation, substance evidence and reporting obligations must be understood before a foreign entity is used.
Permanent establishment and place of management
Actual decision-making, personnel, premises, contracts, representatives and management documentation are central to the structure.
Transfer pricing and group relationships
Functions, risks, intercompany services, documentation, group context and minimum-tax questions need a consistent operating model.
Foundation planning
Liechtenstein foundation planning belongs inside the wider tax structure.
For German entrepreneurs and families, a foundation in Liechtenstein only makes sense when governance, succession, tax classification, bankability and reporting duties are reviewed together.
- Control rights, beneficiaries and distribution rules need to match the tax position.
- Banking, KYC and source-of-funds documentation should be prepared before implementation.
- The structure should be connected to residence, exit tax, CFC and holding-company questions.
Deep dive: Liechtenstein foundation formation
Review international structure