FOREIGN TAX LAW

Foreign tax law deals with tax regulations that affect cross-border activities of companies and individuals.

Double taxation treaties are designed to avoid double taxation. They help to minimize your tax burden

Tax avoidance during departure and tax optimization for periods after transfer of residence abroad

Inheritance Tax International looks at the tax regulations that must be observed in cross-border inheritance cases.

Foreign tax law

This deals in particular with the tax treatment of income, assets and transactions in an international context. Issues such as transfer pricing, exit taxation, addition taxation and foreign family foundations play an important role. In this context, it is important to deal with national and international tax law requirements and to find an individual solution in order to minimize tax risks and to take advantage of tax benefits.

  • International linkages, transfer pricing, profit shifting
  • Change of residence to low-tax countries

  • Exit taxation in the narrower sense, i.e. taxation of the increase in assets in the case of certain shareholdings within the meaning of Section 17 of the German Income Tax Act (EstG)

  • Transfer taxation

  • Foreign family foundation

International linkages, transfer pricing, profit shifting:

International linkages of companies and the associated cross-border transactions can lead to tax challenges. Transfer pricing and profit shifting issues play a crucial role, as they regulate the level of taxation of cross-border transactions between related companies. It is important to observe national and international tax law requirements and find an individual solution in order to minimize tax risks and take advantage of tax benefits. Profit shifting should be avoided in order to ensure an appropriate distribution of tax revenues.

Change of residence to low-tax countries:

A change of residence to a low-tax country can offer tax advantages, but care should be taken here to ensure that there is no abusive arrangement. In addition, national and international tax regulations must be observed. It is important to minimize tax risks and find an individual solution that complies with the tax requirements.

Exit taxation in the narrower sense, i.e. taxation of the increase in assets in the case of certain shareholdings within the meaning of Section 17 of the German Income Tax Act (EStG):

In the event of a departure from Germany, certain participations, such as shares in corporations, may be subject to departure taxation. In this case, the capital gain is taxed at the time of the departure. This provision is intended to prevent taxpayers from “dropping out” of Germany for tax purposes after moving away. It is important to observe national and international tax law requirements and to find an individual solution in order to minimize tax risks and take advantage of tax benefits.

Intracompany taxation:

Addition taxation is a regulation designed to prevent taxpayers from shifting their profits to low-tax countries. Under certain conditions, profits of foreign subsidiaries are added at the level of the parent company in Germany and taxed here. It is important to observe the national and international tax law requirements and to find an individual solution in order to minimize tax risks and take advantage of tax benefits.

Foreign family foundation:

Foreign family foundations can be a way to take advantage of tax benefits in an international context. However, it is important to observe the national and international tax law requirements in order not to run any tax risks. An individual consultation with a specialized tax advisor can help to take into account the tax regulations in Germany and abroad and to find an individual solution.

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