International tax law

Compliance - Avoidance of double taxation - International tax differences

The classic drivers for the expansion of German companies abroad are markets, labor and/or taxes. The top priority when structuring foreign investments should be to protect German company assets and their owners from the access risks of foreign legal systems. This takes precedence over everything else, with tax considerations coming second.

Our international tax advice follows three points in order and weighting: Compliance, avoidance of double taxation and exploitation of low taxes abroad.

Compliance

The legal compliance requirements for reporting, cooperation and documentation obligations are high. They are underestimated, especially by domestic managers.

Avoidance of double taxation

Avoiding double taxation of domestic and foreign profits is a self-explanatory and necessary goal, but in practice it is actually done more badly than well. Causes include, for example, transfer price corrections following tax audits, withholding taxes on dividends, license and management fees.

Avoiding double taxation requires knowledge of the causes. We advise you on recognizing the causes and taking measures to avoid them.

Taking advantage of low taxes abroad

The international community of the OECD has declared war on tax planning by exploiting international tax differences. The last few years have brought disruptive legislative changes, all of which are aimed at taxing profits shifted to low-taxed foreign countries in Germany (BEPS, ATAD, etc.).

Recognizable structuring models, e.g. the distribution of IP rights via low-function foreign licensing companies (also known as IP boxes) or hybrid permanent establishment structures, can only be implemented under special circumstances.

Exit taxation

International mobility is not only economically necessary, it is also politically desirable. However, if this has an impact on state tax entitlements, the tax authorities are no laughing matter.

Many countries use the departure of their citizens as an opportunity to implement an exit tax.

Detailed information can be found in the guide to exit taxation, which we have compiled with the PlattesGroup, Mallorca .

           

Wide-ranging expertise in the field of international tax law:

HLB Schumacher Ganteführer Transfer Pricing

With our group company, HLB Schumacher Ganteführer Transfer Pricing, we have a company specializing in transfer pricing at our side. In order to meet the high demands of the globally networked economy, it provides support with consulting, documentation and tax audits.

HLB Schumacher Ganteführer Transfer Pricing

HLB network

Thanks to our international HLB network, we are able to resolve qualification conflicts between the individual legal systems quickly and reliably with the help of foreign colleagues.

globales Netzwerk HLB Audit Tax Advisory

IFA-Westphalia

We are at the forefront of implementing the latest legal developments. Our partner Prof. Dr. Christian Jahndorf and our Of Counsel Prof. Dr. Till Zech are the initiators and founders of IFA Westfalen. The IFA (International Fiscal Association) is the largest international association of tax lawyers and tax advisors worldwide.

IFA Westfalen

International Legal & Tax Desk (ILTD)

Our International Legal & Tax Desk is also available to domestic companies for their cross-border business activities from Germany to other countries and vice versa. We eliminate language barriers - clients communicate with our specialists in German, English, Spanish or Russian.

Transfer pricing working group

Furthermore, our partner Prof. Dr. Christian Jahndorf and our Of Counsel Prof. Dr. Till Zech have established the Transfer Pricing Working Group. This group discusses the latest developments in the area of global intra-group transactions. Participants are representatives of well-known companies (including DAX companies) who report on their experiences with tax audits, especially in the area of transfer pricing. The working group enables us to pool our experience and utilize it for the benefit of our clients.

Ihre Ansprechpartner:

Prof. Dr. Christian Jahndorf International tax law

Prof. Dr. Christian Jahndorf

Attorney, partner, extraordinary professor Westfälische Wilhelms-Universität Münster

Tel.: +49 (0) 2 51/28 08-153

E-Mail schreiben

Vita

Prof. Dr. Till Zech, LL.M.

Attorney at Law (NY), tax consultant, of counsel

Tel.: +49 (0) 2 51/28 08-153

E-Mail schreiben

Vita

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