Cross-border activities regularly give rise to complex tax issues –both at the corporate level and at the investor level. We assist you in accurately classifying international matters and structuring them in a tax-efficient and sustainable manner, with a particular focus on international tax structures and issues relating to limited tax liability.
A key focus of our advisory services in the inbound context is the classification of domestic-source income and the application of double taxation agreements. In doing so, we specifically assess whether a permanent establishment arises for tax purposes – and what domestic tax consequences result from this.
We provide comprehensive advice on withholding tax issues, particularly with regard to relief options (refund procedures and exemption certificates) and compliance requirements in the area of withholding tax. In addition, we assist you with controlled foreign company (CFC) taxation as well as deduction limitations, especially in connection with financing and licensing structures. We also analyze complex international structures and cross-border financing models with regard to their tax effects.
Furthermore, we support you in implementing the requirements under Pillar Two, including the resulting compliance and reporting obligations.
In the context of cross-border restructurings, we advise you on exit taxation and deemed disposal taxation rules, as well as on business reorganizations involving transfers of functions and the tax valuation of international restructurings. This ensures transparency and legal certainty for your international tax structuring.
News on limited tax liability and international tax structures
When does limited tax liability arise? At what point does a permanent establishment come into existence domestically?
These and other questions are addressed in our latest expert articles, providing you with guidance in the tax classification of international matters.
Do you require support in the tax classification of international matters?