Companies and private clients are faced with several tax regimes in case of inbound or outbound actitivies. On the one hand cross-border actitivies have the risk of dobule taxation but on the other hand those activites have the chance to flexibility in taxation.

In International Taxation our office is focussed on designing tax optimized inbound and outbound investments. We prapare tax opinions and adjust binding rulings with the tax authorities.

We advise in the area of International Taxation especially:

  • Use and interpretation of Double Taxation Treaties
  • CFC tax rules and Foreign Tax Act
  • Moving out taxation
  • Moving in taxation
  • Change of residence or seat of business
  • Tax optimisation of cross-border transaction
  • Taxation of inound and outbound investments
  • Taxation of domestic and international parent and subsidiary companies
  • Taxation of international permanent establishments
  • Expatriate taxation
  • Advice with reporting requirements
  • International succession planning

Double taxation

In an era of digitalisation and globalisation nearly every company is consciously or unconsciously faced with the international tax law.

Subject of the international taxation is to solve cross-border tax issues. To solve cross-border tax issues there is no unified law. Besides the national tax law there are individual double taxation treaties to consider.

The German Federal Ministry of Finance shows in his official letters the current status of negotiation of the double taxation treaties with each country. On the field of income taxes, which is income tax, corporate tax and trade tax, Germany concluded more than 70 individual double taxation treaties with other countries zu aviod a double taxation and to avoid a double non-taxation. The double taxation treaties are generally inspired by a sample treaty developed by the OECD. However each double taxation treaty has national characteristics of the involved countries. Besides the double taxation treaties several protocols and consultation agreements have to be considered.

For solving of international tax issues besides a maximum of profound legal expertise lots of experience and routine is needed to use the double taxation treaties correctly. TLI Steuerberater is specialized to solving most complex international tax issues. Our tax advisors are additonally characterised by the additional qualification called „Fachberater für Internationales Steuerrecht“ which means certified tax expert for international tax law. This additional qualification can just be reached by passing an additional exam for international taxation and by proof that a large number of international tax cases were processed in practice.

Trust on the expertise of our certified tax experts for international tax law in the field of international taxation and the use of dobule taxation treaties especially in case of the acquisition of shares, foreign investments, buy or sell of properties abroad, taxation of permanent establishments abroad or in case of international employee assignments (expatriate cases). The use of double taxation treaties with the USA, Austria, Switzerland, The Netherlands, UK, China, France, etc. is our routine.

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