Cross-border Tax Matters

Legal Advice on International Tax Matters

Inter­na­tion­al busi­ness rela­tion­ships, share­hold­ings and per­son­al wealth arrange­ments can give rise to com­plex tax and cor­po­rate law ques­tions. Dif­fer­ent nation­al tax rules, dou­ble tax­a­tion treaties and cor­po­rate law require­ments may inter­act and need to be con­sid­ered together.

As a Ger­man attor­ney-at-law and cer­ti­fied spe­cial­ist in tax law (Fachan­wältin für Steuer­recht), I advise busi­ness­es, entre­pre­neurs, share­hold­ers and high-net-worth indi­vid­u­als on Ger­man tax law mat­ters with an inter­na­tion­al dimension.

My prac­tice focus­es on the legal assess­ment of Ger­man tax require­ments in an inter­na­tion­al con­text and on devel­op­ing and legal­ly safe­guard­ing appro­pri­ate arrange­ments. In doing so, I take into account my clients’ com­mer­cial and per­son­al interests.

Typical Cross-Border Tax Matters

Inter­na­tion­al tax ques­tions arise both in busi­ness activ­i­ties and through changes in per­son­al cir­cum­stances and wealth arrangements.

My advice par­tic­u­lar­ly covers:

• Relo­ca­tion from or to Ger­many, includ­ing Ger­man exit taxation
• Inter­na­tion­al share­hold­ing and hold­ing structures
• Share­hold­ings in for­eign companies
• Cross-bor­der busi­ness activ­i­ties and investments
• Tax mat­ters relat­ing to for­eign assets and inter­na­tion­al asset transfers
• Cross-bor­der cor­po­rate reorganisations
• Dou­ble tax­a­tion issues and the appli­ca­tion of dou­ble tax­a­tion treaties
• Legal struc­tur­ing and safe­guard­ing of inter­na­tion­al­ly ori­ent­ed cor­po­rate arrangements

My advice may involve prepar­ing a planned trans­ac­tion, review­ing exist­ing struc­tures or clar­i­fy­ing a spe­cif­ic tax law question.

German Exit Taxation and International Shareholdings

A par­tic­u­lar area of my pro­fes­sion­al exper­tise con­cerns Ger­man exit tax­a­tion and the tax con­se­quences of cross-bor­der changes in res­i­dence and share­hold­ing arrangements.

For entre­pre­neurs and share­hold­ers in par­tic­u­lar, relo­cat­ing from Ger­many can have sig­nif­i­cant tax impli­ca­tions. Changes to inter­na­tion­al share­hold­ing struc­tures may also trig­ger tax con­se­quences that should be con­sid­ered at an ear­ly stage.

I have pub­lished sev­er­al arti­cles on Ger­man exit tax­a­tion under Sec­tion 6 of the Ger­man For­eign Tax Act (Außen­s­teuerge­setz – AStG) and the imple­men­ta­tion of the EU Anti-Tax Avoid­ance Direc­tive (ATAD).

A selec­tion of these arti­cles is avail­able under “Pub­li­ca­tions”.

Tax Law, Corporate Law and International Rules

Cross-bor­der mat­ters often can­not be assessed by ref­er­ence to indi­vid­ual tax pro­vi­sions alone.

Cor­po­rate struc­tures, share­hold­ing arrange­ments, con­trac­tu­al agree­ments and lia­bil­i­ty-relat­ed issues may be just as rel­e­vant to the tax treat­ment of a mat­ter as domes­tic tax leg­is­la­tion and inter­na­tion­al treaties.

I assist my clients in under­stand­ing these inter­de­pen­den­cies, assess­ing legal risks and devel­op­ing appro­pri­ate struc­tur­ing options.

The cen­tral ques­tion is how busi­ness or per­son­al deci­sions can be legal­ly imple­ment­ed while tak­ing Ger­man tax and cor­po­rate law require­ments into account.

Typ­i­cal sit­u­a­tions and their legal impli­ca­tions are also dis­cussed in my arti­cle “Coor­di­nat­ing Cross-Bor­der Mat­ters Effec­tive­ly”.

Cooperation with Tax Advisers and International Professionals

Inter­na­tion­al tax mat­ters fre­quent­ly require coop­er­a­tion between sev­er­al pro­fes­sion­al advisers.

I work along­side tax advis­ers, pro­vid­ing inde­pen­dent legal advice on tax law mat­ters, the legal struc­tur­ing of cor­po­rate arrange­ments and the draft­ing and review of rel­e­vant agreements.

Where a mat­ter requires advice on for­eign law, I involve appro­pri­ate­ly qual­i­fied pro­fes­sion­als in the rel­e­vant juris­dic­tion where necessary.

This approach allows dif­fer­ent nation­al require­ments to be con­sid­ered while main­tain­ing a clear dis­tinc­tion between the pro­fes­sion­al respon­si­bil­i­ties of the advis­ers involved.

Fur­ther infor­ma­tion is avail­able under “Coop­er­a­tion with Tax Advis­ers”.

Individual Legal Advice

Cross-bor­der tax mat­ters may require com­pre­hen­sive legal analy­sis and struc­tur­ing. In oth­er cas­es, the focus is on a clear­ly defined indi­vid­ual legal question.

The nature and scope of my advice depend on the par­tic­u­lar cir­cum­stances. This may involve legal sup­port for an inter­na­tion­al cor­po­rate reor­gan­i­sa­tion, a review of an own­er­ship struc­ture or an assess­ment of spe­cif­ic tax impli­ca­tions aris­ing from a pro­posed decision.

I place impor­tance on care­ful analy­sis, clear expla­na­tions of legal issues and prac­ti­cal recommendations.

Frankfurt am Main – Office Location

My law office is locat­ed in Taunus­Turm, in Frank­furt’s finan­cial district.

I advise busi­ness­es, entre­pre­neurs, share­hold­ers and pri­vate indi­vid­u­als based in Frank­furt, the Rhine-Main region and beyond. In inter­na­tion­al mat­ters, I also assist clients who reside abroad or have busi­ness inter­ests out­side Germany.

Meet­ings can be arranged by pri­or appoint­ment, either in per­son at my office or via video conference.

Contact

Would you like to clar­i­fy a cross-bor­der tax mat­ter, review an inter­na­tion­al share­hold­ing struc­ture or pre­pare a legal arrangement?

You are wel­come to briefly out­line your enquiry. I will con­tact you to dis­cuss the appro­pri­ate next steps and the poten­tial scope of my engagement.