International Tax Law

Investing abroad

We help German companies structure their foreign investment in the way optimal for tax purposes.

Possibilities include, e.g.

  • Direct business from within Germany
  • Setting up a branch office, manufacturing site or sales agency abroad
  • Participation in a foreign partnership
  • Founding a foreign limited liability company

Considering both German and foreign law, we develop tax planning to provide a basis for your decisions. In so doing, a great number of tax law provisions are to be taken into account, for instance regulations about

  • Transfer pricing and transfer of functions
  • Double taxation agreements
  • European law guidelines and jurisdiction of the European Court of Justice
  • Regulations on loss offsetting
  • Special documentation and disclosure obligations
  • Provisions on abuse

We support you with competent consultation in the following areas, among others:

  • International tax planning with holding structures
  • Optimising tax deducted at source
  • Issues of profit splitting between the domestic and foreign parts of the company
  • Transfer pricing and documentation
  • Cross-border value-added tax questions
  • Reimbursement of prepaid tax
  • Exemption procedures

For tax law issues in other countries, we have recourse to co-operations with partners domiciled there.