1. How can I avoid being taxed in Germany in the future (extended limited tax liability)?
2. How can I pay myself from my company (German GmbH) in the future?
3. What would he do regarding exit tax in my situation?

• Generally speaking, it ultimately depends on the Double Taxation Agreement (DTA). If one is liable for tax in the destination country according to the DTA, then the issue is actually already relatively clear (according to his statement), because one is simply tax resident only there. In many countries, this applies, for example, if one is there for more than 180 days in a calendar year and at the same time no longer has a permanent residence in Germany (deregistration, no possession of keys, etc.).
• Even if one then falls under the extended limited tax liability (e.g., by moving to a low-tax country or having German income or German assets), Germany can at most only tax German income; this is usually income if one still receives a "German" salary, capital gains, rental income, etc.; although rental income is always taxed in Germany anyway.
• He additionally advises moving assets out of Germany, e.g., ETFs and cash. I didn't quite understand why, but perhaps a reason is that it otherwise increases the risk for extended limited tax liability?

• Here he seemed a bit clueless and rambled for quite a long time about the danger that the GmbH would now have a permanent establishment abroad, which would lead to too much complexity regarding international taxes.
• My suggestion to hire a German managing director, found a foreign company, and then issue (arm's length) invoices to the GmbH through the foreign company, he considered plausible. However, the suggestion came from me, not from him - not much came from him here.
• Generally, he said that the risk of a tax audit for small companies is generally very low. And something like that would only be looked at during a tax audit.

• Here he unfortunately seemed very weak. It was unclear to me whether he was not very competent or simply tended to talk a lot and digress heavily (in doubt, the latter), but it was simply very difficult for me to get him to make any suggestion at all.
  His (very) general ideas consisted of:
• A foundation must "fit" the life model - so if one, for example, already has children and wants to bequeath something to them in a tax-optimized way anyway, then a foundation could make sense, with which the exit tax would also be eliminated (here are my articles on the German foundation and the Liechtenstein foundation). His colleague who sets up foundations is currently "heavily utilized" and they have long waiting times for it.
  (Both somehow not helpful - as I later read, among other things, in a book on German foundations, there are certainly other reasons to set up a foundation; furthermore, one can partly even do this alone)
• The double holding, i.e., the contribution of an existing holding GmbH into a holding GmbH & Co. KG, he described as the "final boss of the tax administration," presumably because the structure is so complex. He then talked very generically about it for a bit longer, but it somehow did not become clear whether this could be a suitable solution for me or not.
  (Later it turned out that this would be the suitable solution for me - but his very generic stories here were unfortunately not helpful for that, making it essentially a missed opportunity)
• He also mentioned that setting up a holding GmbH & Co. KG is sometimes difficult: It must be commercially active (e.g., through the sale of products/services to subsidiaries) and it needs a German managing director. According to him, this costs at least €3k / month
  (I ended up setting it up more cheaply)
• He said that the Juhn people generally didn't have the internal expertise to set up the holding GmbH & Co. KG and that they actually delegate that to other people.
  (I got the impression during discussions with the Juhn people that they very well had the expertise for it - in the end, however, I cannot confirm that)

• He suggested founding a foreign company after moving away, making it as profitable as possible, and potentially moving back to Germany. The reason for this is that one then receives a sort of tax credit, which is also based on an absurdly high valuation of the company (13.75 * profit); so, simply put, a "reverse exit tax," because one is now "bringing" a company to Germany.
  (I later learned from the Juhn people that this is quite complex and it is sometimes easier to simply sell the assets of the foreign company to a new GmbH and give the GmbH a loan for this.)
• He said that the tax offices in Bavaria are apparently very problematic regarding exit tax, as they now handle processing centrally in one office (?), waiting times are long, and sometimes everything is interpreted extremely strictly.
• There are a few other options for structuring the exit tax, namely the sale, e.g., to a family member while retaining usufruct, or a so-called "atypical silent partnership." In his opinion, however, both constructs would not really withstand an audit (interesting, since other tax advisors sell the atypical silent partnership, among other things, as a solution for the exit tax).
• Generally speaking, a German foundation has the advantage that the contribution of assets is often easier (keyword: need for exemption test)
  (But works only with operational GmbHs that one holds privately, as I later learned myself)
• He also said that setting up a foundation through his firm takes quite a long time (months?) and that they sometimes lose clients because of it. The process seems to be quite frustrating.

Summary: Robert Lackmann / Rose Partner on Exit Tax