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
Monitoring of vesting periods
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
Separation of private properties from operating activities
Tax clauses in SPA/APA
Tax monitoring of investments
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.
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
VAT refund procedure
Tax registration obligations
Optimization of input tax keys
VAT clauses in purchase agreements
Representation in special VAT audits, unannounced audits and tax field audits
Fiscal court proceedings
Chain and triangular transactions
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.
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
Domestic tax declaration
Coordination with foreign tax colleagues in the country of residence
Tax structuring due to double tax treaties
Avoidance of exit taxation
Stock option modells
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
Sale of companies or assets
Tax valuation of companies
SPA, APA (including tax clauses)
Tax planning for a transaction structure
Choice of legal form
Tax function and risk analysis
Tax group structures
Transformation into another legal form
Capital and organizational restructuring
Loss utilisation strategies
Tax-optimized business and assets structures
Separation of ownership and management position
Foundations and administration of estates
Inheritance tax valuation of companies
Structuring of tax benefits
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.