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International Tax Law

Business goes global, taxes stay local: Although globalization has left its mark on almost all areas of business, tax remains largely a matter for individual countries. Companies that operate across borders are confronted with many different tax regimes that not only have an impact on inbound and outbound activities, but also offer new structuring options.

At the same time, there is a risk that tax authorities in multiple countries will claim taxation rights. One of our great strengths is to anticipate such conflicts and take action to avoid them.

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 expertise that flows into their daily work for our clients. Where necessary, we bring in colleagues from our network of excellent partner firms abroad, in particular the Taxand network.

From structuring advice to dispute resolution

Our international tax law practice focuses on structuring domestic investments abroad and foreign investments in Germany. In cross-border projects, we’re on hand every step of the way – from the planning stage to the launch of a solution that combines tax considerations with the greatest possible legal certainty. Joining forces with colleagues in other countries, we analyze tax consequences, examine structuring options, and put them into practice. This includes contract drafting. Our interdisciplinary approach is a key advantage here. Often we take the lead in the taxation element of restructuring international corporations, and cross-border mergers and acquisitions.

International dispute resolution and avoidance of double taxation

Increasingly, cross-border structures are subject to close scrutiny by the tax authorities in Germany and abroad. Reasons for this include the growing complexity of international tax law and an increasingly fierce “allocations battle” between the tax authorities in different countries. We represent our clients both in tax audits and in any subsequent appeal and court proceedings. Where business profits are taxed in multiple states and thus twice, we conduct mutual agreement and arbitration proceedings. Our excellent contacts with tax authorities in Germany and abroad are invaluable here. Having worked on many successful projects, we have in-depth knowledge of how the tax authorities in different countries share information.

Transfer pricing, licenses, transfers of functions

Flick Gocke Schaumburg has particular expertise in transfer pricing, licenses, and the transfer of functions between affiliated companies and permanent establishments. We create transfer pricing systems, identify their tax consequences (for example by comparing tax burdens, calculating withholding tax burdens, and examining customs and foreign trade law consequences) and negotiate with the international tax authorities (primarily in connection with advance pricing agreements). In addition, we prepare documentation on the appropriateness of the transfer prices applied. We also have special expertise when it comes to the taxation of permanent establishments.

Succession and exit taxation

Moving abroad regularly triggers tax consequences. The same is true of cross-border estate planning and cases of succession with an international dimension. We advise our clients with regard to both exit taxation and tax-optimized succession planning that provides legal certainty. In many cases we succeed in avoiding exit taxation after discussions with the tax authorities.

Internationally connected

We are a member of Taxand. Where necessary, we involve colleagues from other Taxand firms in our work. We also have an excellent network of leading local tax firms.

All contacts and experts

Client advisory in international tax law

  • Cross-border investments (inbound/outbound)
  • Cross-border corporate reorganizations and changes of legal form
  • Cross-border mergers & acquisitions
  • Transfer pricing and transfers of functions
  • International taxation of permanent establishments
  • International minimum taxation (Pillar Two)
  • Country-by-country reporting
  • 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

News and insights

04.12.2023 | External Event
Webinar: Die internationale Unternehmerfamilie: Rechts- und Steuerfragen bei international mobilen Gesellschaftern
22.11.2023 | External Event
Die internationale Unternehmerfamilie: Rechts- und Steuerfragen bei international mobilen Gesellschaftern
29.10.2023 | External Event
IBA Annual Conference 2023
24.10.2023 | FGS Event
Abendforum Steuerzentrierte Rechtsberatung
20.10.2023 | External Event
Fachberaterlehrgang Internationales Steuerrecht
20.10.2023 | External Event
Fachberaterlehrgang Internationales Steuerrecht – Grundzüge des deutschen Internationalen Steuerrechts
28.09.2023 | Press Release
Flick Gocke Schaumburg wins twice at the ITR Tax Awards
20.09.2023 | FGS Blog
Entwurf einer EU-Verrechnungspreisrichtlinie
21.08.2023 | FGS Blog
BFH: Inländische Betriebsstätte eines ausländischen Dienstleisters
26.07.2023 | FGS Blog
Mitteilungspflicht über innerstaatliche Steuergestaltungen (Teil 10)
26.06.2023 | Press Release
JUVE Tax Awards 2023: Flick Gocke Schaumburg named Law Firm of the Year for tax disputes
16.06.2023 | Press Release
Best Lawyers: Flick Gocke Schaumburg again named Law Firm of the Year for Tax Law and Succession Planning & Foundations