We help German companies

structure their foreign investment

in the way optimal for tax purposes.

Possibilities include, e.g. • Direct business from within Germany • Setting up a branch office, manufacturing site or sales agency abroad • Participation in a foreign partnership • Founding a foreign limited liability company Considering both German and foreign law, we develop tax planning to provide a basis for your decisions. In so doing, a great number of tax law provisions are to be taken into account, for instance regulations about • Transfer pricing and transfer of functions • Double taxation agreements • European law guidelines and jurisdiction of the European Court of Justice • Regulations on loss offsetting • Special documentation and disclosure obligations • Provisions on abuse We support you with competent consultation in the following areas, among others: • International tax planning with holding structures • Optimising tax deducted at source • Issues of profit splitting between the domestic and foreign parts of the company • Transfer pricing and documentation • Cross-border value-added tax questions • Reimbursement of prepaid tax • Exemption procedures For tax law issues in other countries, we have recourse to co-operations with partners domiciled there.