Tax Advisory Services
Reliable and anticipatory Tax Planning:
Tax Law in Germany as well as in the context of International Tax Law is characterized by a continous change legislation and jursiprudence. Annual legislative initiatives are accompanied by various administrative rulings and interpretations of jurisprudence. The application of Tax Law has become increasingly complex and challenging for practitioners.
The legislator tends to utilize the constiutional right of retroactive application to decrease the tax payers Options of tax structuring. In addition to the domestic tax law, constiutional implications as well as European Law and International Tax Law are to be considered.
This increase in complexity of Tax Law represents a growing challenge for tax structuring.
It is our commitment to ensure a continous overview of the legal Environment and thereby ensuring a foresighted and current tax structuring for our Clients.
Continous Tax Consultancy and Tax Structuring
Tax Compliance Work in the context of the legal obligations, specifically:
- The preparation of annual financial statements with and without plausibility check under the consideration of the preconditions of the German Banking Act (Kreditwesengesetz, KWG) and Bank-specific Company Ratings.
- continous preparation of tax filings
- Active Engagement in continous and ongoing tax audits
- Tax Consulting in the context of the current business and legal environment
- Tax Enforcement, judicial and non-judicial tax procedures in Germany relating to German Fiscal Courts
- Coordination and active discussion with the fiscal authorities concerning specific and unique tax issues (e.g. binding resolutions).
Tax Planning, specifically:
- Tax-optimized Structuring and Planning for Partnerships and Corporations (Active tax-oriented structuring of Performance and service relationships between shareholder and affiliated entityas well as intra-group),
- Models and structures for optimization of tax rate for specific taxes, e.g. Real Estate Transfer Tax and Trade Tax Optimization,
- Tax structuring in the context of crisis situations, specifically optimization and ensuring usability of tax loss carryforwards, avoidance of restructuring gains and tax-optimized contributions by shareholders (loans, guarantee etc.)
- advise relating to tax issues on Company Pension Schemes and structuring of concrete Schemes
- tax-oriented employee participation models, direct participations, stock Options, tracking stocks
Special Areas of Consulting
Restructuring and Reorganization / Optimization of Legal Form
Restructuring and Reorganization in the context of the German Restructuring Act (Umwandlungsgesetz, UmwG) and the German Tax Restructuring Act (Umwandlungssteuergesetz, UmwStG), specifically Change of legal form, merger, spin-off and outsourcing.
Tax Due Diligence
Tax Due Diligence due to Mergers & Acquisitions, IPOs and Equity Financing.
Tax optimization and structuring of Company purchases and sales, Share Deals and Asset Deals as well as tax clauses in contracts.
Company and Asset Succession
Drafting of a succession structure within families and between third-parties (MBO, MBI).
International Tax Law
- Advise in the election of the appropriate and beneficial organizational and legal forms
- Tax Compliance relating to foreign subsidiary and permanent establishments
- Profit Allocation of permanent Establishments in Germany and abroad
- Assistance in the drafting of Transfer Pricing Guidlines and Transfer Pricing Studies
- Tax Planning in the context of companies and group structures, specifically
- Tax Exemption of Dividends and Capital Gains
- Ensuring Tax Deductibility of Expenses as well as Tax Loss Carryforwards
- Avoidance of CFC Rules and the application of the German Foreign Tax Act (Außensteuergesetz, AStG)
- Reduction of Withholding Taxes
- Optimization of Shareholder Debt Financing
- Optimization of Holding Structures as well as identification of appropriate and beneficial Holding Residences and Structures
- VAT / Sales Tax in the context of cross-border services and deliveries
- VAT Reimbursement
- Avoidance of Double Taxation due to cross-border activities
We have a access to a network of international colleagues with country-specific competencies. Based on a proven and successfull cooperation we can ensure an effective and timely cooperation with our colleagues on cross-border Projects.
We have focused our services on the consulting of domestic and foreign companies and investors in the context of inbound and outbound business activities.
Phone: 0049 89 / 242 916 0
Fax: 0049 89 / 242 916 99
Phone.: 0049 89 / 242 916 0
Fax: 0049 89 / 242 916 99