International Tax Law
Globalization is no longer a matter just for big corporations. Small and medium-sized companies have been operating across borders for years now. But they have to deal with legal and tax requirements, both at home and abroad, that are often as unknown as they are complex, all the more so because tax authorities in virtually every country want to protect tax revenues and increase them whenever possible. So they’re giving much closer scrutiny to cross-border matters.
On the other hand, the differences in legal and tax systems also offer many opportunities to reduce or optimize tax impact.
We can help you thread your way through the jungle of international tax laws. We offer suggestions about tax structuring, and point out risks.
Take advantage of our expertise in organizing your investments abroad, and in choosing international sites. We can also help you optimize tax rates, restructure within your corporate group, and organize cross-border transactions.
When you relocate functions and post employees abroad, we help you avoid both unwanted taxation and double taxation.
Our services at a glance
Consulting on international structures
- Tax-optimized organization of planned international activities and international restructuring of your company, using comparative studies of tax impact
- Assistance with choosing a location
- Tax optimization of cross-border services
- Organizing intra-group financing structures
- Assistance with relief from foreign withholding taxes
- Advice about cross-border offsetting of losses
International tax administration
- Identifying tax risks for your agency, establishment, commercial representative or subsidiary in another country
- Assistance in complying with domestic and foreign tax regulations for your investment abroad
- Reviewing options for simplifying administration, for example by restructuring your investment abroad
Inbound tax advice
- Advising subsidiaries and establishments of foreign investors in Germany about all German tax issues
- Assistance with meeting German tax obligations
- Reviewing options for optimizing tax impact
- Assistance with structuring international transfer pricing
Outbound tax advice
- Advising on structuring investments in subsidiaries, establishments or equity interests abroad, in close cooperation with our international partners and in compliance with both domestic and foreign tax law
- Reviewing the domestic tax impact of existing investments abroad
- Advising on tax optimization for investments abroad
- Assistance in structuring international transfer pricing
International transfer prices / Relocations of functions
- Advising on structuring transfer pricing systems
- Assistance with preparing and updating transfer pricing documentation required by law
- Implementing international transfer pricing systems under advance pricing agreements (APAs) with domestic and foreign tax authorities
- Reviewing the tax impact of cross-border relocations of functions, especially in cases of duplicate functions
- Obtaining tax recognition from the relevant authorities for transfer pricing systems
All-inclusive assistance with posting employees to other countries, or hiring foreign employees in Germany (expatriates)
- Reviewing economic advantages of international postings for the company
- Drafting company posting guidelines
- Clarifying all legal, tax, social-security and organizational issues associated with postings
- Reviewing legal, tax and social-security consequences of specific postings
- Consulting on questions of payments and liability for employee withholding tax
- Preparing individual tax returns for posted employees both in Germany and in cooperation with our international partners abroad
- Consulting on the reintegration of employees after their return, from legal, tax and social-security viewpoints
International taxation of private individuals
- Advising on avoiding double taxation of income earned abroad, including in cross-border transactions and in disposals of real estate abroad
- Reviewing the tax consequences of relocating a residence abroad (especially German exit tax)
- Clarification of tax consequences of relocating assets abroad, both under German tax law and under foreign tax law in cooperation with our international partners
- Reviewing inheritance-tax aspects of holding assets abroad
- Advising on avoiding double taxation of foreign assets in cases of gifts or bequests
