International tax law has become more and more important in contemporary life. Nowadays, neither economical nor personal relations finish at the border of a state whereas fiscal jurisdictions are still determined by such borders. Even though there are first tendencies within the European Union to improve this, a sound international tax planning strategy is still absolutely necessary. This is even more true for cross border relations with countries outside of the EU.
In practice, internationally active companies and individuals are often confronted with unknown tax difficulties whose complexities are also rarely transparent.
Listed below are some selected issues for the practice area „International Tax“, which provide a first overview of our business activities for companies and individuals:
- Choice of legal form for cross border investments
- Planning of group and holding structures
- Internationally active partnerships
- Taxation of permanent establishments
- Intra-group deliveries and services
- Limited tax liability of foreign residents
- Foreign income of German residents
- Movement or posting to foreign countries
- Possession and transfer of foreign assets
- Special issues for foreign investments
- Items of German CFC-Legislation
- Consideration of European Tax Law
- Issues of foreign tax law systems