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Nexia Ebner Stolz

International Tax Law

Globalization is no longer a matter just for big corporations. Small and medium-sized companies have been operating across borders for years now. But they have to deal with legal and tax requirements, both at home and abroad, that are often as unknown as they are complex, all the more so because tax authorities in virtually every country want to protect tax revenues and increase them whenever possible. So they’re giving much closer scrutiny to cross-border matters.

On the other hand, the dif­fe­ren­ces in legal and tax sys­tems also offer many oppor­tuni­ties to reduce or opti­mize tax impact.

We can help you thread your way through the jungle of inter­na­tio­nal tax laws. We offer sug­ges­ti­ons about tax struc­tu­ring, and point out risks.

Take advan­tage of our exper­tise in orga­ni­zing your invest­ments abroad, and in choo­sing inter­na­tio­nal sites. We can also help you opti­mize tax rates, restruc­ture wit­hin your cor­po­rate group, and orga­nize cross-bor­der tran­sac­ti­ons.

When you relo­cate func­ti­ons and post emp­loyees abroad, we help you avoid both unwan­ted taxa­tion and dou­ble taxa­tion.

In Nexia – a world­wide net­work of inde­pen­dent acco­un­ting, audi­ting and tax advice firms – we have a strong, capable part­ner that gives us access to the exper­tise of 620 part­ner com­pa­nies in more than 90 coun­tries.

Our ser­vices at a glance

  • Con­sul­ting on inter­na­tio­nal struc­tu­res
    • Tax-opti­mi­zed orga­niza­tion of plan­ned inter­na­tio­nal acti­vi­ties and inter­na­tio­nal restruc­tu­ring of your com­pany, using com­pa­ra­tive stu­dies of tax impact
    • Assi­s­tance with choo­sing a loca­tion
    • Tax opti­miza­tion of cross-bor­der ser­vices
    • Orga­ni­zing intra-group finan­cing struc­tu­res
    • Assi­s­tance with relief from for­eign with­hol­ding taxes
    • Advice about cross-bor­der off­set­ting of los­ses
  • Inter­na­tio­nal tax admi­ni­s­t­ra­tion
    • Iden­ti­fying tax risks for your agency, estab­lish­ment, com­mer­cial rep­re­sen­ta­tive or sub­si­diary in ano­ther coun­try
    • Assi­s­tance in com­p­lying with domestic and for­eign tax regu­la­ti­ons for your invest­ment abroad
    • Revie­wing opti­ons for sim­p­li­fying admi­ni­s­t­ra­tion, for example by restruc­tu­ring your invest­ment abroad
  • Inbound tax advice
    • Advi­sing sub­si­dia­ries and estab­lish­ments of for­eign inve­s­tors in Ger­many about all Ger­man tax issues
    • Assi­s­tance with mee­ting Ger­man tax obli­ga­ti­ons
    • Revie­wing opti­ons for opti­mi­zing tax impact
    • Assi­s­tance with struc­tu­ring inter­na­tio­nal trans­fer pri­cing
  • Out­bound tax advice
    • Advi­sing on struc­tu­ring invest­ments in sub­si­dia­ries, estab­lish­ments or equity inte­rests abroad, in close coope­ra­tion with our Nexia part­ners and in com­p­li­ance with both domestic and for­eign tax law
    • Revie­wing the domestic tax impact of exis­ting invest­ments abroad
    • Advi­sing on tax opti­miza­tion for invest­ments abroad
    • Assi­s­tance in struc­tu­ring inter­na­tio­nal trans­fer pri­cing
  • Inter­na­tio­nal trans­fer pri­ces / Relo­ca­ti­ons of func­ti­ons
    • Advi­sing on struc­tu­ring trans­fer pri­cing sys­tems
    • Assi­s­tance with pre­pa­ring and upda­ting trans­fer pri­cing docu­men­ta­tion requi­red by law
    • Imp­le­men­ting inter­na­tio­nal trans­fer pri­cing sys­tems under advance pri­cing agree­ments (APAs) with domestic and for­eign tax aut­ho­ri­ties
    • Revie­wing the tax impact of cross-bor­der relo­ca­ti­ons of func­ti­ons, espe­cially in cases of dup­li­cate func­ti­ons
    • Obtai­ning tax recogni­tion from the rele­vant aut­ho­ri­ties for trans­fer pri­cing sys­tems
  • All-inclu­sive assi­s­tance with pos­ting emp­loyees to other coun­tries, or hiring for­eign emp­loyees in Ger­many (expa­tria­tes)
    • Revie­wing eco­no­mic advan­ta­ges of inter­na­tio­nal pos­tings for the com­pany
    • Draf­ting com­pany pos­ting gui­de­li­nes
    • Cla­ri­fying all legal, tax, social-secu­rity and orga­niza­tio­nal issues asso­cia­ted with pos­tings
    • Revie­wing legal, tax and social-secu­rity con­se­qu­en­ces of spe­ci­fic pos­tings
    • Con­sul­ting on ques­ti­ons of pay­ments and lia­bi­lity for emp­loyee with­hol­ding tax
    • Pre­pa­ring indi­vi­dual tax returns for pos­ted emp­loyees both in Ger­many and in coope­ra­tion with our Nexia part­ners abroad
    • Con­sul­ting on the rein­te­g­ra­tion of emp­loyees after their return, from legal, tax and social-secu­rity view­po­ints
  • Inter­na­tio­nal taxa­tion of pri­vate indi­vi­duals
    • Advi­sing on avo­i­ding dou­ble taxa­tion of income ear­ned abroad, inclu­ding in cross-bor­der tran­sac­ti­ons and in dis­po­sals of real estate abroad
    • Revie­wing the tax con­se­qu­en­ces of relo­ca­ting a resi­dence abroad (espe­cially Ger­man exit tax)
    • Cla­ri­fi­ca­tion of tax con­se­qu­en­ces of relo­ca­ting assets abroad, both under Ger­man tax law and under for­eign tax law in coope­ra­tion with our Nexia part­ners
    • Revie­wing inhe­ri­tance-tax aspects of hol­ding assets abroad
    • Advi­sing on avo­i­ding dou­ble taxa­tion of for­eign assets in cases of gifts or bequ­ests

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