International Tax Law

As globalisation progresses, cross-border issues are becoming increasingly important for companies. Not only large corporations operate internationally; small and medium-sized companies are also setting up production or sales units abroad in order to be able to compete on the international stage. At the same time, many employees are taking advantage of the opportunity to work abroad for a certain period – at a foreign subsidiary, for example. Crossing borders gives rise to a host of com-plex tax issues, such as foreign taxation, final taxation in Germany (so-called disjunction), avoidance of double taxation or adherence to reporting and compliance regulations. Our experts offer support and assistance in all areas of international tax law and European tax law so that you can avoid any pitfalls abroad.

The international tax landscape is becoming increasingly stringent due to national or supranational (OECD, EU) measures. This bears tax risks in connection with essential business investments abroad. At the same time, however, there is tax competition between countries, for example through reductions in international corporate tax rates, particularly in Eastern Europe. Other signs of this can be seen in the introduction of preferential tax systems, such as the so-called licence boxes for companies or, more recently, the flat-rate tax in Italy for private individuals who have transferred their tax residence from outside the country. While the fundamental freedoms under European Union law within Europe’s internal market protect cross-border activities, companies that exploit foreign tax advantages may face having to repay state aid that has been received unlawfully (Art. 107 TFEU).

We offer comprehensive practical and professional expertise in all areas of international and European tax law. Our team of experienced, international tax consultants and lawyers help companies achieve their corporate goals with the maximum of legal certainty and tax efficiency.

Our services

Our services include comprehensive and holistic advice in the field of international and European tax law, tailored to your company’s needs.

These services in particular include:

  • Tax-optimisation of your foreign investments with regard to German law (in particular applying the exemption method, taking into account the various switch-over and revisionary clauses) and, where foreign law is involved, in cooperation with Mazars' foreign offices
  • Advice with regard to German controlled foreign corporation (CFC) rules
  • Restructuring of international companies and corporate groups
  • Foreign investments via production sites and partnerships
  • Observance of compliance rules, in particular with regard to reporting requirements for cross-border tax structures
  • Setting up international holding structures
  • Advising on statutory changes resulting from the implementation of the Anti-Tax Avoidance Directive (ATAD), in particular with regard to CFC rules and hybrid structures
  • Emigration of natural persons and avoidance of tax risks in disjunction scenarios
  • Advising and planning with regard to German withholding tax relief
  • Real estate investments in Germany
  • Defence advice in connection with company audits and appeal proceedings concerning all international tax law and European tax law issues
  • Legal representation before German fiscal courts and the Federal Fiscal Court (BFH) in disputes related to international tax law
  • Legal representation before the European Court of Justice (ECJ) in disputes related to European tax law, such as fundamental freedoms, state aid and secondary law
  • Advising in connection with political developments in the field of international tax law and European tax law
  • Advising other tax consultants in the field of international and European tax law.

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Tax advisory

Whether capital market oriented international group, owner managed business or high net worth individual; whether domestic or international activities – tax issues are a decisive factor for all business transactions. Therefore it is our ambition to develop optimized tax strategies in order to achieve a long-term and sustainable reduction of your tax burden.