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International


Our clients appreciate our service.




Our partners of the firm are qualified with more than 15 years of international experience in multinational firms as experts and tax advisor in international tax law. We maintain partnerships in all major cities of Germany and have close links with tax an law firms in Europe, the USA and Asia.






International tax planning

In times of globalisation and national mobility, one of our focuses is outbound advice for our domestic clients and investments to Germany by non-residents. In addition to the taxable presence of permanent establishment or agent permanent establishment, issues of avoidance of double taxation under foreign tax law and double tax treaties and the multiple compliance obligations play a crucial role for the principal place of management. Not to be underestimated, there are also pitfalls in VAT-exempt EU or export supplies. In addition, the acquisition of companies or parts of companies, including tax-optimized financing structures, is often the first step in the transition to foreign markets. Our partners within the firm have many years of international expertise in the practical implementation of tailor-made structures and the avoidance of cross-border tax pitfalls on the other hand.






Real estate structuring

Besides legal specifics, the acquisition of domestic real property is also tax-wise connected with pitfalls and risks, especially in the use of tax havens. Particularly real-estate owning companies have to consider tax optimization measures in terms of real estate transfer taxes by choosing a legal form. Further tax risks entail issues of transfer of going concerns for VAT purposes. Our partners as tax advisors have over ten years of international experience and support you in structuring the acquisition of real estate, the tax clauses and tax-optimized sales.

Real estate transfer tax planning
  • Tax-neutral transmission in the group
  • Low-tax transfers of real estate companies
  • RETT-Blocker-structures
  • Monitoring of vesting periods

Restructuring
  • Legal form of real estate companies
  • Restructuring of real estate portfolios
  • Tax deferral structures
  • Structures for avoiding corporate splits

Avoidance of trade tax burden
  • Shielding effect of commercial property trading
  • Structures for an extended trade tax reduction

VAT exposures
  • Separation of private properties from operating activities
  • Tax clauses in SPA/APA
  • Tax monitoring of investments






International VAT

Despite European harmonization of VAT, divergences in cross-border supply chains, exports or the reverse charge procedure exist, due to local laws. We support you, in the field of international tax law, in respect of the tax registration of foreign companies in Germany, ongoing VAT compliance and representation before tax authorities. Our partners are proven experts in international VAT and members of corresponding national VAT advisory boards.

Internal processes
  • VAT-check of internal processes
  • Electronic invoicing business
  • In-house VAT manuals for typical business transactions
  • Tax paper on VAT issues
  • Monthly VAT filings and cross-border declarations

Filings abroad
  • Assembly facilities
  • VAT refund procedure
  • Tax registration obligations

Real estate
  • Optimization of input tax keys
  • VAT clauses in purchase agreements

Tax controversies
  • Representation in special VAT audits, unannounced audits and tax field audits
  • Legal objections
  • Binding rulings
  • Fiscal court proceedings
  • Customs inspections

Supply chains
  • Chain and triangular transactions
  • Foreign warehouse
  • Import VAT and customs declaration







Secondment of employees

The temporal secondment of employees in inbound and outbound scenarios has become part of common practice, particularly of temporary project assignments, in companies. We support both companies in fulfilling their tax obligations and income tax issues of seconded employees both domestically and at foreign locations.

Employer advice
  • Wage tax planning
  • Tax calculation for salary fixing domestically and abroad
  • Tax planning regarding secondment agreements
  • Charge back agreements and transfer pricing
  • Avoidance of permanent
  • Tax optimization on remuneration
  • Advice on social security treaties
  • Audits in international assignments
  • Tax-motivated severance payments

Employee advice
  • Arrival-Interviews
  • Domestic tax declaration
  • Coordination with foreign tax colleagues in the country of residence
  • Tax structuring due to double tax treaties
  • Avoidance of exit taxation
  • Employment premium
  • Stock option modells








M&A Transactions

In times of globalisation and national mobility, one of our focuses is outbound advice for our domestic clients and inbound investments to Germany by non-residents. In addition to the taxable presence of permanent establishment or agent permanent establishment, issues of avoidance of multiple taxation and international agreements by the double taxation agreement, as well as the multiple compliance obligations play a crucial role for the selection of the formation. Our partners have decades of experience in the tax support of domestic and cross-border corporate transactions of any company size. A good tax advice on the acquisition process can both shorten the duration of the acquisition transaction as lead to a tax-optimized acquisition structure. We support our clients with due diligence, tax-related agreements and in the negotiations with the parties involved.

M & A transaction
  • Analysis of alternative options for potential sales
  • Due Diligence
  • Sale of companies or assets
  • Tax valuation of companies
  • SPA, APA (including tax clauses)
  • Tax planning for a transaction structure

Corporate structures
  • Choice of legal form
  • Tax function and risk analysis
  • Tax group structures
  • Company leasing
  • Transformation into another legal form
  • Capital and organizational restructuring
  • Loss utilisation strategies

Company succession
  • Tax-optimized business and assets structures
  • Anticipated succession
  • Separation of ownership and management position
  • Business integration
  • Foundations and administration of estates
  • Inheritance tax valuation of companies
  • Structuring of tax benefits
  • Pool agreements







Compliance

We support our clients in their annual local tax filing obligations as well as the preparation of financial statements in English. Next to VAT declarations this includes all declarations for corporate income tax purposes.