Specialized in International Tax Law and Litigation
With a focus on combating unwanted structures, international tax law has grown increasingly complex over the past decades. Avoiding exposure to international tax issues has therefore become ever more challenging. In this environment, sound compliance and thorough audit preparation are just as essential as actively defending your rights and challenging excessive laws before national and higher courts. Our experienced team supports you with specialist knowledge and a comprehensive advisory approach to any questions you may face, allowing you to focus on the operation of your business.
Our Expertise
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International Taxation
Operating in an international context involves navigating complex regulations and treaties across different jurisdictions to ensure optimal tax treatment for individuals or business activities. These cases often entail intricate decisions regarding transfer pricing, entitlement to and application of tax treaties, steering clear of anti avoidance rules, tax treaty application and entitlement. Special attention has to be paid to ensure meeting existing compliance requirements under the applicable tax laws.
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Exit Taxation
Relocating from Germany or transferring your tax residence abroad can trigger exit taxation, especially for individuals with substantial corporate shareholdings - potentially resulting in significant tax liabilities even without an actual sale. We provide comprehensive advice on all aspects of exit taxation, including assessing your specific situation, exploring structuring and deferral options, and supporting you in dealings with tax authorities. Early planning is crucial to avoid pitfalls and ensure your financial flexibility.
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Tax Litigation
Navigating tax disputes requires foresight, expertise, and strategic preparation. We cover the full spectrum of proceedings - from appeal procedures and cases before domestic fiscal courts to representation before the Federal Fiscal Court, the Constitutional Court, and the European Court of Justice.
Successful litigation begins long before a court hearing. We place particular emphasis on preparing cases as early as the appeal procedure and ensuring a consistent narrative and the right strategy. By aligning arguments and evidence at an early stage, we maximize the chances of achieving favorable outcomes while safeguarding your rights at every level of jurisdiction.
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Criminal Defence
Tax-related criminal proceedings are among the most complex and sensitive areas of legal practice and can have a significant impact on your business operations. We provide comprehensive support in defending clients in criminal tax matters as well as in all other tax offence matters.
Our services range from voluntary disclosures and regularization processes if something has gone wrong, ensuring risks are mitigated and compliance is restored, to strategic defense work in complex matters such as cum ex. By combining strategic foresight with strong procedural expertise, we protect our clients’ rights and guide them safely through every stage of tax-related criminal proceedings.
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Pillar 2
The global minimum tax poses unprecedented challenges for the tax department of large Multi National Entities with a turnover of above EUR 750 Mio. and, more recently, also for their accounting departments. The new set of rules require specialized guidance in implementation strategies, addressing unique queries, transaction advisory, and tax planning. Comprehensive knowledge in international tax frameworks and accounting principles as well as a rigorous process implementation are essential to ensure compliance in this field of global tax policy.