International tax law
Advancing globalisation and digitalisation mean that international aspects can hardly be disregarded in any entrepreneurial activity today. At the same time, international tax law is becoming even more complex due to the increased cooperation at the level of the European Union and the OECD. Therefore we already specialised in international tax law at an early stage and accompany companies and individuals in their worldwide activities since decades.
Transfer pricing and reporting obligations
Permanent establishments and profit determination
Activities abroad often lead to permanent establishments, with the consequence that income has to be apportioned between Germany and abroad, and often specific permanent establishment profit split rules have to be observed. In some cases, an application must be made to transfer the bookkeeping abroad. Depending on the complexity, we prepare a memorandum in which all these points are recorded when we take on the mandate or when you start your business, to ensure evertything is taken care of.
Withholding tax relief and exemption
We investigate for you whether there is an obligation to withhold withholding taxes on licences, dividends and interest and prepare applications for relief or exemption from withholding taxes for you or on your behalf for your suppliers. Subsequently, we take over any necessary declaration obligations. If necessary, we coordinate cooperation across the border, for example in the case of internationally active groups with tax departments from different countries.
Private individuals and international tax liability
We assist private individuals even in complicated cases with declaration obligations in two or more countries, such as in the case of extended limited tax liability pursuant to § 2 AStG or dual residency. Our staff is fluent in English and most of them has many years of practical experience with international tax law.
CFC taxation (controlled foreign companies)
The extension of the scope of CFC taxation leads to an increaed number of cases in which a declaration obligation is ignored, with serious financial and even criminal consequences. In order to minimise risks, we analyse your structures with regard to the possible application of CFC taxation and, if necessary, prepare the corresponding returns.
Private individuals and moving out of Germany
Leaving Germany does not automatically mean that your tax obligations no longer apply. You may be subject to exit taxation under Sec. 6 of the German Foreign Tax Act (AStG) or ,if you move to a country with low taxation, to the extended limited tax liability under Sec. 2 AStG ; in certain cases, this also includes the UK and Portugal. We advise you on your declaration obligations.