For people leaving Germany, Switzerland & Austria
The three-tier structure: Earn tax-efficiently. Build wealth. Protect wealth.
Have you left Germany, Switzerland or Austria behind, or are you on your way? Then this is the structure that finally lets you earn at a low tax rate or tax-free, build your wealth and keep it safe from the state for good. Residence, operating company, holding company and foundation, cleanly combined, completely legal, planned and set up by us.
The problem
The state is already planning how to get at your wealth
Anyone building wealth in the German-speaking world does not just pay high taxes, they can also see where things are heading. For entrepreneurs, social insurance is becoming compulsory. Crypto is now taxed. Next on the list are precious metals, then property sales, then a wealth tax, and the EU is already working on a central register of assets. The direction is clear, and it hits those who have planned ahead first.
An account abroad does not solve the problem on its own. Nor does a change of residence on its own. What you need is a structure in which three things work together: where you live, who holds your wealth, and how it is built up and protected. If one of the three levels is missing, the whole concept breaks, usually exactly when it matters: when you leave, when you invest, when you build wealth.
The solution
The three tiers
Your residence in the Philippines
Every structure stands or falls with your tax residence. You need a residence outside the German-speaking world that really works. Our choice for maximum flexibility is the Philippines, for concrete reasons:
- Double tax treaties with Germany, Austria and Switzerland. That is the decisive advantage over countries such as Paraguay, Panama or Dubai: without a treaty, you have to spend at least 183 days a year there. With the Philippine treaty, a genuine residence is enough, without rigid minimum days of presence.
- No minimum stay. You do not have to be there permanently.
- No automatic exchange of information (no CRS).
- No controlled foreign company rules (no CFC rules) that tax your foreign companies to death.
- No tax on foreign income and no visa needed to live there.
- Very affordable: for the price at which you get only a mailbox address elsewhere, here you have a real flat from around $160 a month.
The residence set-up includes a real flat, a tax number, a registration certificate, utility bills, a registered mobile number and, on request, a driving licence, almost all remotely. Plus your personal USD account on the ground, with no CRS reporting.
Your US LLC, through which you earn
Your income runs through a US LLC. Combined correctly with the residence from tier 1, that means legally tax-efficient or tax-free income, sound also under Germany's Foreign Tax Act (Außensteuergesetz) and its extended limited tax liability for people who have left. On top come the advantages that hardly anyone names so clearly:
- No tax return for the LLC in the sense you know from Germany.
- No bookkeeping obligation as with a German GmbH.
- Anonymity: the ownership structure is not publicly visible.
The LLC gets its own bank account outside the EU.
A holding company and a foundation that hold and protect your wealth
Above the LLC sits a holding company in St Vincent. And this is the point almost everyone overlooks: this holding company is not just the formal owner of the LLC, it is the company that holds your actual wealth: shares, gold, crypto, even property. It acts as a blocker and bundles your assets in a protected shell outside the EU.
At the top sits the Nevis foundation. It holds the holding company, and from here on the wealth no longer formally belongs to you, without you losing control. Nevis is on no black list and no grey list, has well-tested foundation law and leaves you, as an entrepreneur, workable control, without the drawbacks of Liechtenstein (effort, loss of control) or Panama (EU grey list, reputation). The holding company and the foundation each get their own bank account outside the EU.
The holding company acts as a blocker: it protects your wealth from tax claims that would otherwise hit it directly. If you carry out your move cleanly and know and manage the relevant deadlines, the clock is on your side. That is the part we work through with you in detail.
Nevis foundation → St Vincent holding company (holds your wealth) → US LLC (operating), carried by your residence in the Philippines.
What we deliver
What we do for you
Analysis of your overall situation: income, asset classes (shares, property, crypto, precious metals), family, estate goals
Setting up your residence (for example in the Philippines, almost entirely remotely)
Formation of the foundation, holding company and operating company, matched to each other
Banking set up to fit the structure, in jurisdictions outside the EU
Ongoing support, so that the structure still holds in five years' time
All completely legal: income belongs in your tax return as always, where you are liable to tax. What this structure gives you is not concealment but privacy, protection and the right tax burden: the one the law provides for, not the maximum. If you want to open a non-EU bank account while you still live in Germany, you will find the right options at freedombanking.plus.
Your expert
Friedrich Hennegriff
In-house asset protection expert
A former private banker who has invested in the capital markets since the age of twelve. Property, securities, crypto, precious metals: Friedrich knows the asset classes from the investment side AND from the protection side. Together with our tax and structuring team, he plans your structure and puts it in place with you.
👉 Book an appointmentWho it is for (and who it is not for)
Suitable for
Entrepreneurs, professionals and investors who really can and want to leave Germany, with significant wealth or ongoing income, and who think in generations.
Not suitable if
You stay living in Germany. Without a genuine move, none of these tiers works, and we will tell you just as plainly in the first conversation. You can still prepare today: we also open accounts in more than 30 non-EU jurisdictions while you still live in Germany, completely legally.
Prices & ordering
One package, one structure, fully set up
No modular kit, no hidden tiers: you order the complete three-tier structure and we put it in place with you, including all companies, the foundation and the bank accounts outside the EU.
What is included:
3 personal calls with Friedrich Hennegriff, worth £1,500: analysis of your overall situation, design and fine-tuning of your structure
Residence in the Philippines, a real flat, tax number, registration certificate, utility bills, mobile number, driving licence on request, almost all remotely
Personal USD account in the Philippines without CRS, initial deposit $12,000, which does not have to stay in the account
US LLC including a bank account outside the EU
St Vincent holding company (holds your wealth) including a bank account outside the EU
Nevis foundation including a bank account outside the EU
Ongoing support & administration from the second year: £6,900 a year (annual renewal and compliance of the LLC, holding company and foundation, including a nominee secretary and a nominee member of the foundation's management board, upkeep of the structure, ongoing availability).
Because individual components can vary with your starting point (for example additional companies or asset classes), we confirm the binding final price during onboarding. The rent for your flat in the Philippines (around $160 to $600 a month) is paid directly to the landlord and is not included in the package.
Still unsure? Book a consultation first
Frequently asked questions
FAQ
The state is planning with your wealth. Time you did too.
Book your consultation with Friedrich Hennegriff now. You go through your situation together, and you get a concrete proposal for your structure with a cost overview, honestly, even if the answer is that you are not ready yet.
👉 Book an appointment