German citizen, deregistering soon. I build AI agents and automation systems for small businesses — mostly German clients but expanding internationally. Revenue: 50–150k€/year. Clearly commercial (gewerblich), not freelance (freiberuflich).
My current thinking: Georgia VZC (0% corporate on foreign revenue) + Georgian tax residency (double taxation agreement (DBA) with Germany → kills §2 AStG) + Paraguay cédula as backup for maximum travel flexibility.
Looking for real experiences on:
- Georgia VZC in practice — does it actually hold up as a real permanent establishment (Betriebsstätte)? Minimum presence needed for tax residency certificate?
- Paraguay-only without a double taxation agreement (DBA) — anyone running a commercial (gewerblich) business with German clients from Paraguay? How's the risk in reality?
- US LLC + territorial residency — does anyone use this long-term successfully as a German?
Not looking for "see a tax advisor" — already booked. Want lived experience from people who've actually done this.