International tax law & transfer pricing
Our colleagues keep a close eye on your tax affairs, including in relation to international matters.
Key areas of our consulting services include:
- Acquisition and establishment of foreign subsidiaries
- Domestic investments by foreign companies
- International location planning
- Cross-border company conversions
- Secondment of staff
- Relocation of private individuals
- Tax advice for foreign private individuals
- Relocation of foreign tax residents to Germany
- International customs and VAT law
- Transfer pricing and transfer pricing documentation
- International tax burden comparison
Questions raised by our clients include:
- What factors should be taken into account when expanding business operations abroad?
- What is the process for a foreign parent company to set up a domestic company?
- What specific considerations apply to investments abroad? For example, how should W-8 forms be completed in this context?
- What tax and legal consequences can be expected when relocating production abroad?
- What needs to be taken into account when foreign group companies use trademarks or other intangible assets?
- In which cases is there an obligation to withhold withholding tax?
- How can excess withholding tax be reclaimed?
- In which scenarios is transfer pricing documentation required?
- What evidence must be provided regarding transfer pricing during a tax audit?
- What framework conditions apply when foreign employees work in Germany or German employees work abroad?
- What factors should be taken into account when purchasing a holiday home?
- What consequences might moving abroad entail?
- What steps should be taken when foreign assets are transferred or become part of an estate?
- How might retrospective transfer pricing adjustments affect the customs value and VAT that have already been declared?
With markets becoming increasingly interconnected and corporate structures growing ever more complex across national borders, the challenges surrounding the taxation of cross-border transactions are mounting. The aim here is to minimise the risk of double taxation without having to accept any restrictions on international business activities.
In the complex field of international corporate taxation, we are your point of contact for the tax structuring of inbound and outbound investments. We advise you on setting up cross-border holding structures, relocating companies abroad, and the cross-border transfer of licences and capital. We possess particular expertise in the area of transfer pricing between domestic and foreign associated companies.
We also assist private individuals who wish to relocate their residence, either temporarily or permanently, within Germany or abroad. Unintended tax consequences associated with such a move can be avoided through targeted structuring. We also advise on the legal and tax aspects of international inheritance cases, as well as on the taxation of foreign creative professionals and sportspeople working in Germany.
