Mr. A, who works as an executive for a big Kuwaiti oil company and is resident in Kuwait (which has 0% income tax) has been sent by his employer to Germany to become the company’s CEO European operations. He expects to he stay there for at least 8-10 years and will take his family with him.
As he is concerned about the high personal income tax rates in Germany (which are up to 48.5%), Mr. A wants to know whether he can mitigate his exposure to German tax as a result of pre-migration tax planning.
Mr. A can transfer funds and other properties owned by him to a trust established by him before moving to Germany. The trust will administer the property for beneficiaries, who he has determined.
Mr. A should not be named as a beneficiary, as long as he is a tax resident of Germany, and the same applies to any of the other beneficiaries.