While globalization has left its mark on virtually all areas of business life, tax remains largely a matter for individual countries. Companies that operate across borders are confronted with many different tax regimes, which not only have an impact on these entities’ inbound and outbound activities, but also offer new structuring options.
Think-Tank for International Tax Law
Flick Gocke Schaumburg was one of the first firms in Germany to dedicate itself to international tax law. Our lawyers and tax advisors always address international taxation issues very early in their analysis of a company’s legal affairs. They demonstrate their academic and practical edge in the knowledge that flows into their daily work for our clients. We often involve experts from other countries and can draw on a network of excellent partner firms in the key markets worldwide.
From Planning Advice to Dispute Resolution
Our international tax law practice focuses on structuring domestic investments abroad and foreign investments in Germany. We provide tax-law opinions before, or assist our clients during, international activities. We obtain binding rulings and negotiate with the tax authorities. Often we take the tax lead in restructuring international companies and corporate groups, and cross-border mergers and acquisitions. If a court dispute is unavoidable, we represent our clients in cross-border litigation, arbitration and mediation proceedings.
Risk of Double Taxation
Cross-border trading regularly harbors the risk of double taxation. To avoid or at least to reduce this risk, we agree key facts with international tax authorities, for example, in advance pricing agreements. Having worked on many successful projects, we have in-depth knowledge of how the tax authorities in different countries share information.
Transfer Pricing, Licenses and Business Restructuring
Flick Gocke Schaumburg has particular expertise in transfer pricing, licenses and business restructuring between affiliated companies. We advise our clients on international tax comparisons, and on all customs and foreign-trade issues.
Our Expertise in International Tax Law includes:
- Cross-border investments (inbound/outbound)
- Cross-border corporate reorganizations and changes of legal form
- Cross-border mergers and acquisitions
- Transfer pricing and business restructuring
- Expatriation and immigration of individuals and business entities
- German CFC rules
- Cross-border succession planning
- Foreign family foundations and trusts
- Mutual agreement and arbitration procedures
- International exchange of information
- Tax litigation including representation before the CJEU
- Representation and defense in state-aid proceedings in tax matters