International Tax Law

International tax law contains many challenges and stumbling blocks that need to be considered in cross-border activities.

Cross-border activities can be very different, so that a separate critical assessment is always required. Examples include sales activities abroad, employee postings, founding a company, setting up a permanent establishment for tax purposes, distributions or license payments from or abroad, transfer prices or moving abroad. The examples in this context are as diverse as its tax implications, which result from:

- Double tax treaty

- Foreign Tax Law

- Special withholding tax

- Anti-abuse rules

- Unilateral and bilateral regulations to avoid double taxation

- transfer pricing

- Foreign tax law

- jurisprudence

- Decrees of the financial administration

- Reporting and documentation requirements

Cross-border activities can only be carried out in a tax-optimized and legally secure manner if all areas are appropriately assessed for the respective facts. Because it should always be noted that in the case of cross-border activities, at least two countries always request taxation. Therefore, the focus should be on a tax-optimized structure on the one hand, and on avoiding double taxation on the other. In addition, it should not be forgotten that incorrect application of the law can often lead to criminal tax consequences at home or abroad. But the missing or insufficient reporting and documentation obligations can also lead to significant fines and tax payments.