We support you in any discussions and disputes you might encounter with the German tax administration, from tax audit support to assistance in appeal and court procedures or in competent authority procedures, such as Advanced Pricing Arrangements (APAs) and Mutual Agreement Procedures (MAP).

We believe in a transparent, fact-based approach and in fair cooperation with the tax administration. These ensure a clear understanding of the issues at hand as well as the position taken. Our commitment to you involves being firm in our positions, advocating vigorously on your behalf while maintaining a constructive and collaborative relationship with tax authorities in order to achieve long-lasting, sustainable solutions.

In technical tax matters this may involve reconciling a position upfront by way of requesting binding rulings or pro-actively addressing critical matters with the tax auditors. In the area of transfer pricing it may be sensible to secure a certain set-up with an APA or to take advantage of a tax audit to apply for a subsequent ruling that could maintain a once achieved solution for future periods.

In court procedures we are supported by experts with long standing practical experience up until the Federal Fiscal Court, the German Constitutional Court as well as the European Court of Justice. This ensures that once you have taken the decision to challenge the position of the tax administration in front of a judge, your case is handled with the highest expertise and most rigorous care.

Our services comprise reviewing and enhancing your transfer pricing structures, as well as supporting you in tax audits where your transfer pricing system is challenged, to ensure alignment with global standards.

We advise you on the design, implementation, documentation or optimization of internal transfer pricing strategies in accordance with international standards. Our comprehensive consulting approach also keeps an eye on follow-up issues, such as function shifting, unbundling and the interaction with other tax regimes e.g. CFC taxation or the global minimum taxation.

With the Anti-Tax-Avoidance-Directive (ATAD), CFC taxation has been introduced in all Member States of the European Union. German CFC Rules have also experienced notable changes that add to the already existing complexities. However, where the taxpayer entertains actual economic activities in another jurisdiction, German CFC rules should not apply and a diligent review of your set-up can usually prevent their application.

Whether a tax treaty applies and whetehr a taxpayer can benefit from certain tax treaty provisions is often subject to a diligent analysis.

Understanding and applying the correct tax treaty provisions is essential for optimizing tax obligations and maintaining compliance. We are specialized and experienced in analyzing the correct application of tax treaties and assessing tax treaty entitlements. This process can prove very challenging, influenced by either factual complexities and/or the introduction of ever new anti-avoidance rules.

We offer expert support in navigating these complexities, helping you understand the nuances of tax treaties and how they apply to your specific situation. Our services also comprise support in refund procedures for German withholding taxes on dividends, interests and license payments as well as the application for tax exemption certificates with the German Central Tax Office (BZSt).