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a.merkel
a.merkel, Rechtsanwältin; LL.M. Eur.
Category: German Law
Satisfied Customers: 2154
Experience:  1.+ 2. Staatsexamen; LL.M.(Master of Law)
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I have dual citizenship (German-American). I am planing to

Customer Question

Hi,
I have dual citizenship (German-American). I am planing to work in Hong Kong for less than 12 months. There is neither a double tax agreement in place between HK and Germany, nor with HK and the US. How can I avoid to pay taxes in all three countries?
I was thinking about canceling my residancy here in Germany (I do not reside in the US).
In this scenario, where will I need to pay taxes and what tax sceames will apply?
(I am single, 23 years old, just finished college, might be going back after have worked in HK for some time, will earn 4700€/month as an employee)
I am quite nervous and would be so greatful if you could help.
Regards,
J.
Submitted: 1 year ago.
Category: German Law
Expert:  a.merkel replied 1 year ago.

Dear Customer ,

I will answer your questions based on the information as follows:

1. There is neither a double tax agreement in place between HK and Germany, nor with HK and the US. How can I avoid to pay taxes in all three countries?

You're right, There is no double taxation agreement between HK and D or HK and USA in the area of ​​income . While such exist with China , but Hong Kong is excluded from the scope .

The unlimited income tax liability in Germany arises when you have a residence in Germany. You have no residence in Germany, if you dont rent an apartment or your condo have sold or rented.

The tax liability in the United States is based on nationality and is regardless of whether or not you live in the United States.

To avoid a unlimited tax liability in Germany, you must canceling your residence here. You can have a limited tax liability if you have achieve any income in Germany, for example rental income of a rented condo.

You can reach the avoidance of taxation in the United States, if you give up your citizenship. If you don't want this, you remain subject to tax in both countries. I point out, that there is a tax information exchange agreement between HK and the United States.

2. In this scenario, where will I need to pay taxes and what tax sceames will apply?

see answer above.
I can't exactly tell you how much taxes in Hong Kong and in the United States you may have to pay. The average tax rate in HK is about 17%. In the United States 25%.

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