Consulting services in the area of international tax services

International tax planning (outbound & inbound)

Setup of your business idea abroad and optimization of the corporate structure of your group of companies internationally

Transfer Pricing

Initiation of and support for reactive and preventive instruments to eliminate transfer pricing conflicts (mutual agreement procedure, APA procedure)

Support of tax audits with questions of international tax law up to the support of joint audits

Establishment of permanent establishments and permanent establishment taxation

Group withholding tax optimization, especially for dividends, financing and licenses

Cross-border M&A and cross-border restructuring (e.g. relocation of functions)

Structuring with regard to CFC rules (e.g. German taxation of foreign income)

Employee secondment

Cross-border financing (thin cap rules, hybrid financing instruments, cross-border leasing, etc.)

Strategies for cross-border loss utilization

Cross-border conversions and tax implications

European fundamental freedoms and corporate taxation

Withdrawal taxation