Expertise
International Tax Law
Capital moves freely around the world. To structure cross-border matters both legally and tax-efficiently requires expertise. Whether you are establishing a foreign permanent establishment, expanding your business abroad or relocating your residence, we help you navigate the complexities of international taxation. We protect you from the consequences of double taxation, advise on German exit taxation ("exit tax") and assess the opportunities offered by foreign tax incentive regimes ("welcome taxes").
Services
Advice on Cross-Border Matters & the Application of Double Taxation Agreements
Application of double taxation agreements in cases involving dual residence, permanent establishments and cross-border income from dividends, interest and royalties.
Strategic Planning for Exit Taxation and Relocation of Residence
Planning relocations and changes of tax residence, including German exit taxation under Section 6 of the German Foreign Tax Act (AStG), together with an assessment of foreign tax incentive regimes.
Structuring Inbound and Outbound Investments
Advice on investments in and through foreign companies under the German Foreign Tax Act, particularly in connection with holding structures and low-tax jurisdictions.
Permanent Establishments and Transfer Pricing
Structuring and documentation of transfer prices between associated enterprises, including compliance with German transfer pricing documentation requirements.
Holding Structures
Structuring international shareholdings, from establishing a holding company through to ongoing advice on distribution policy.
In Practice
Opportunities arise where others see borders. The tax aspects of relocating abroad are usually far more complex than they first appear.
German exit taxation often results in immediate taxation of unrealised gains, which can initially appear discouraging. Combined with foreign tax incentive regimes and specific "welcome tax" provisions in destination countries, however, the picture becomes considerably more nuanced. Those who analyse the overall situation carefully transform an apparent tax obstacle into a predictable business case.
Initial Consultation
Book a Consultation
If you have a specific question relating to an international tax matter, you can book an initial consultation.
