A major focus of our advice is international tax law. This concerns companies as well as natural persons.
All areas of economic or private life that involve contact with foreign jurisdictions and fiscal administrations require intensive advice on the consequences of cross-border entrepreneurial activities. International tax law is an essential component of tax structuring and tax planning, as states are in natural tax competition with each other to present themselves as attractive locations for investors and companies. Companies can make use of these advantages in a completely legal manner and are also obliged to do so from a business perspective.
In the area of international tax law, we benefit from a network of advisors in the European Union but also in many third countries such as the USA and England.
Cross-border mergers and restructurings are very common.
Within Europe, taxpayers benefit from the Merger Directive. This makes it possible to relocate parts of companies within the European Union tax-free if the instruments of the transformation law are used. Such special regulations do not exist for third countries. Careful tax planning is required here.
The legal relationships between associated companies must be carefully structured in accordance with the transfer pricing guidelines.
Here we support you with the necessary documentation and accompany you in the tax audit.
Inheritance tax law is the area of tax law most prone to genuine double taxation.
While there is a dense network of double taxation agreements in the area of income tax, there are only a few of these in the area of inheritance tax. Therefore, multiple taxation can often occur in the case of an estate that is spread over several countries. Cases in which almost the entire estate is subject to taxation are not uncommon. This is why careful planning is necessary, especially in the area of international inheritance cases. Of course, this applies not only to inheritance tax, but also to gift tax, i.e. anticipated succession.