From theory to practice: New guide to international tax procedural law

In their new handbook “Internationales Steuerverfahrensrecht – Streitbeilegung und Streitvermeidung” (International Tax Procedural Law – Dispute Resolution and Dispute Avoidance), Flick Gocke Schaumburg experts Dr. Daniel Liebchen and Dr. Noemi Strotkemper provide a comprehensive and practical overview of the key procedures. Spanning some 450 pages, the work offers a systematic overview of all procedures for international dispute resolution and dispute prevention. The topics covered include intergovernmental mutual agreement and arbitration procedures, as well as advance mutual agreement procedures, joint audits and risk assessment procedures. Furthermore, the handbook sets out how these instruments relate to national appeal procedures.

In this new publication, the experts shed light on an area of law in which there is an increasing need for guidance. In Germany, transfer pricing adjustments and resulting disputes continue to rise. Mutual agreement and arbitration procedures involving Germany have featured prominently in OECD statistics for over a decade. In addition, intergovernmental dispute prevention procedures are becoming significantly more important in practice. Preventing or efficiently resolving international tax disputes is increasingly relevant for many businesses and their advisors.

At the same time, differing legal bases, procedural frameworks and stakeholders complicate the practical application of dispute resolution and dispute prevention procedures. This is where the handbook proves to be invaluable. It thoroughly examines the various procedures and their legal bases – from filing an application, through conducting the procedures, to their conclusion and the transposition of the results into national law. This presentation is based on the relevant provisions of international law, EU law and national law; it draws on the relevant case law of the tax courts and administrative practice; and it also takes into account the latest OECD recommendations. The handbook systematically presents and classifies all dispute resolution and dispute prevention procedures within a single volume, supplemented by separate sections covering the various legal bases – a feature that makes this a particularly valuable piece of work.

“The legal framework for dispute resolution and conciliation procedures between states has become much more complex and has undergone significant changes over recent years – both at European and global level,” explain Dr. Liebchen and Dr. Strotkemper. “Our aim was to create a compact reference work that covers both the legal principles and practical experience and provides potential solutions.”

To complement the legal and systematic analysis, the authors have included practical advice at key points, drawing on their many years’ experience in handling international tax disputes and dispute resolution procedures. These guidelines are intended, in particular, to help in realistically assessing strategic options, to avoid typical procedural risks, to prepare applications correctly and, finally, to ensure that the intergovernmental solution is transposed into national law.

The handbook “Internationales Steuerverfahrensrecht” (International Tax Procedural Law) (as at 31 December 2025) is aimed at experts in the fields of tax advisory services, auditing, the legal profession, tax administration, tax litigation, business, and higher education.

It is now available in the Beck Shop via: https://www.beck-shop.de/liebchen-strotkemper-internationales-steuerverfahrensrecht/product/35612983?srsltid=AfmBOopXATwWNeQ6zuKqSaJoORwrLnispieomQVaGuBvD8dWUGBQ5lhR

Dr. Daniel Liebchen is a tax advisor and partner at the Hamburg office of Flick Gocke Schaumburg. For more than 15 years, he has been advising multinational companies across various sectors on transfer pricing, the transfer of functions, corporate restructuring and valuation issues. A particular focus of his work is advising multinational companies on their defence during tax audits relating to transfer pricing issues.

Dr. Noemi Strotkemper is a lawyer, tax advisor and associate partner at Flick Gocke Schaumburg’s Düsseldorf office. She has been advising clients on international tax procedural law for over 15 years. Her practice focuses on providing defence advice on matters of international tax law and transfer pricing, in particular in relation to international mutual agreement and arbitration procedures, international dispute resolution procedures, and national appeal and tax court procedures. <<<