Companies operating in global markets are facing many complex tax issues in all jurisdictions which they are engaged in. For the companies and their advisors this requires an international perspective besides sound knowledge of country-specific tax and legal regulations.
Double Taxation Issues
Entering into cross-border transactions and contracts will face businesses with tax matters in foreign jurisdictions and might, at home, also trigger domestic taxation. Bilateral agreements on the avoidance and mitigation of such double taxation are in place between certain states.
However such agreements will not apply in all bilateral cases. Businesses engaged in cross-border issues will have to examine whether an double taxation agreement is in place for their case or, if not, what measures can be taken in the national tax jurisdiction to avoid or mitigate double taxation.
The focus of our international tax division is on cross-border corporate and income tax issues. We advise our clients e.g. on the structuring holding company, cross-border finance matters; cross-border taxation of owners and users of an asset; withholding taxes on cross-border transactions; company reorganization and rationalization of legal entities abroad and in Germany.
Transfer Pricing Issues
Multi-national businesses with foreign operations will aim for overall, global long-term business benefits by chosing the right set for intercompany transfer prices. They will also install an international supply chain management to adjust profit allocation.
In this respect, International businesses are facing tough documentation requirements with regard to intercompany transfer prices. Our transfer pricing experts support international businesses in reviewing, documenting, and adjusting their transfer pricing policies in accordance with their business and finance strategy.