International Tax Consultancy

The crossing of borders raises a variety of complex tax issues, such as foreign taxation, taxation upon relocation (the so-called exit tax), avoiding double taxation or adherence to reporting and compliance regulations. Our experts are at your side in all areas of international and European tax law, helping you avoid potential pitfalls abroad.

The legal framework in the area of international tax law is becoming increasingly stringent due to national or supranational (OECD, EU) measures. This entails tax risks for economically necessary foreign investments. At the same time, however, states are competing for tax income, which is apparent in the decrease in international corporate tax rates, particularly in Eastern Europe. This is also reflected in the introduction of preferential tax systems such as the so-called ‟license boxes” for companies or, more recently, the flat-rate tax in Italy for private individuals who move there. While the fundamental freedoms of EU law protect cross-border activities within the European internal market, the use of tax advantages abroad sometimes entails the risk of receiving prohibited state benefits that must be repaid (Art. 107 AEUV).

We offer you comprehensive practical and academic expertise in all areas of international and European tax law. Our team of experienced, internationally active tax consultants and lawyers will ensure that you can realise your business objectives in a legally compliant and tax-efficient manner.

Services

Our services comprise end-to-end advice tailored to your company in the field of international and European tax law.

These include in particular:

• Tax-optimised structuring of your foreign investments in line with German law (in particular the use of exemption methods and the various switchover and fallback clauses), as well as in line with foreign tax law, in cooperation with the international offices of the Forvis Mazars Group,
• Advice on the taxation of controlled foreign corporations in Germany,
• Restructuring international companies and corporate groups,
• Foreign investments via permanent establishments and partnerships,
• Adherence with compliance regulations, particularly with reporting obligations for cross-border tax arrangements,
• Establishing international holding structures,
• Advice on legal changes resulting from the implementation of the Anti Tax Avoidance Directive (ATAD), particularly as it affects add-back taxation and hybrid structures,
• Relocating natural persons and avoiding tax risks in exit tax situations,
• Advice and structuring of relief from German withholding taxes,
• Real estate investments in Germany,
• Advice on defending against tax audits and appeal proceedings on all matters of international and European tax law,
• Legal representation before German fiscal courts and the Federal Fiscal Court (BFH) in disputes over international tax law,
• Legal representation before the European Court of Justice (ECJ) in disputes over European tax law, such as basic freedoms, benefits or secondary law,
• Advice on political developments in international and European tax law,
• Advice for other tax consultants in international and European tax law.