A central topic for our specialists is efficient international tax planning that is aimed both at German companies with interests abroad and at foreign investors with activities in Germany. The determination of differences in tax systems and rates of tax provides scope for tax optimization, which can, for example, be implemented via holding, licensing and financing companies. In our concepts, issues of corporate structure play just as much a part as do loss exploitation, repatriation of profits and exit strategies.
At companies operating internationally, the transfer prices for internal supplies and services have a decisive effect on the tax rate. Frequently these prices are rigidly tested by the fiscal authorities or even questioned in their entirety. We support you with the development and documentation of transfer pricing models in line with the market and support you in enforcing them in relation to the fiscal authorities.
Despite the increasing virtualization of work, international secondments of employees within companies are still regularly encountered. Such secondments raise, both for the employer and for the employee, numerous questions regarding tax issues, starting from payroll accounting via hypothetical tax calculations as far as the submission of income tax returns in the host country. Moreover, secondment also has a social insurance-related dimension. Our specialists will be pleased to also support you with the solution of these problems.
Besides direct taxes, indirect taxes are increasingly gaining in importance in international business transactions, as an increasing number of states identify these as an additional source of revenue. For example, several Gulf states introduced VAT at 1st of January 2018, other Gulf states will follow in the next years. In China “business tax” has only recently been replaced by turnover tax. Even if these tax systems provide for a refund of the tax accrued at the respective preliminary step, compliance with the local registration, documentation and declaration obligations as a rule causes high expenditure and effort for the persons/entities liable to pay taxes. In the case of tax systems with a cumulative tax burden effect, further financial disadvantages threaten. These issues occur both in the case of intragroup transactions and in transactions with outside third parties. The specialists of our international network support you in minimizing the risks from indirect taxes and in meeting the local compliance requirements.