Advice on questions concerning international tax law
Advice concerning the accrual of customs duties and import sales tax on imports of private small aircraft in international air traffic.
(Upstream) mergers of foreign subsidiaries
Tax advice to a national real estate company concerning the matter of dissolving a Dutch subsidiary by way of an (upstream) merger with the German parent company.
Cross-border software license agreements
Tax advice to an internationally positioned internet company concerning the matter of dealing with cross-border software license agreements between the individual affiliate companies.
Tax advice to a natural person resident abroad in connection with a number of planned investments in Germany, in particular in the area of real estate projects.
Advice in connection with the tax implications of the results of the foreign audit of parts of a company based abroad on the parts of the company in Germany.
Transfer of limited partners’ interests abroad
Tax advice in connection with the transfer of limited partners’ interests to a public limited company based in Switzerland.
Advice on the question of the tax status of a foreign holding in Germany.
Structure of a real estate project
Tax advice on the holding structure of domestic and foreign investors in a commercial real estate project in Germany
Tax advice on the distinction between unlimited and limited tax liability as well as concerning the provisions of the double tax treaty upon commencement of a doctorate in Switzerland.
Tax advice on the tax liability in the case of bonus payments following expatriation resulting from a previous employment relationship in Germany.
Advice on acquisitions and restructuring
Second opinion on questions concerning taxation and the fiscal feasibility of an acquisition and financing concept for a complex international corporate restructuring.
Advice on structure and location
Advice on tax structuring in relation to the restructuring and choice of location of a national middle-sized group of companies concerning the optimal location for the worldwide provision of exclusive engineering services, in particular regarding questions as to choice of location in Ireland and Hong Kong, as well as the problems connected with the taxation of foreign sourced income (distinction between active and passive income, etc.).
Advice and representation during a tax audit
Advising of various real estate companies – both in Germany and abroad – conducting business in Germany and with an internationally operating real estate group and banks as investors on tax-related questions concerning the tax audit, in particular with relation to the aspects of international and cross-border taxation.
Utilization of foreign losses pursuant to the Marks & Spencer decision
Advice on possible concepts for the utilization of losses made by a foreign subsidiary in Germany on the basis of the new rules set out by the ECJ in its decision in the case of Marks & Spencer (ECJ, Judgment from 13th December 2005, Rs. C-446/03, Marks & Spencer, DStR 2005, p. 2168 = IStR 2006, p. 19).
Advice on the extended business tax reduction for real-estate companies
Advising of a German, internationally operating real estate group on questions concerning the limited duration of the extended business tax reduction in connection with the disposal of interests to partnerships as a result of changes to the law in section 7 (1) and section 9 no. 1 (6) Business Tax Act (GewStG).
Tax advice in relation to the planned expansion of the scope of business of a company in Germany through business premises and / or subsidiaries in the USA and Hungary.
Tax advice in relation to the transformation of German partnerships and corporations in a number of cases.
Tax law attorneys
Taxation of mulitnational and multicorporate enterprises
International tax law
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Telefax: (+49) 40 284 09 55 22
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