Extended Limited Tax Liability - Slovakia
Hello,
Before 2020, I was employed in Germany and paid taxes and social security contributions there. Since January 1, 2020, I have a Slovakian employment contract and also pay taxes and social security contributions in Slovakia. In 2020, my wife and I also had a residence in Germany (at my parents' house), which we deregistered by December 31, 2020. Since then, our apartment in Slovakia is the only residence and we only visit Germany occasionally.
I have been assuming that since January 1, 2021, I am only partially tax liable in Germany. I do not have any properties or other investments in Germany, but I do have a German bank account with a depot holding a significant amount of international stock ETFs. The capital gains so far are relatively high (approximately equivalent to one year's salary). I have exempted myself from the withholding tax as a non-resident at the bank.
My plan was to sell the ETFs this year, as there is no tax on stock capital gains in Slovakia if they are held for at least a year. Now I have some questions:
1) Could I become subject to an extended limited tax liability in Germany? I have been fully tax liable in Germany for more than 5 years in the last 10 years.
1a) Is Slovakia considered a low-tax country?
1b) Would the sales of international stock ETFs be considered domestic income under an extended limited tax liability? Can I assume that I only need to pay taxes on the stock capital gains in Slovakia?
2) I have been offered a German employment contract with another employer. I would maintain my Slovakian residence and work from home office for a large part of the time. I would work in Germany for 5 days once a month and stay in a hotel there. I would not establish a residence in Germany. My potential employer and I are aware of the social security consequences (Slovakian social security). Also, I know that I have to pay the majority of taxes in Slovakia and pay taxes in Germany for the days when I work there.
2a) Would I be partially tax liable for the income earned in Germany for the days worked there, or could there be an extended limited tax liability?
2b) Could there be a tax liability for the capital gains in Germany if I sell the international stock ETFs at my German bank?
Thank you very much and best regards.
