International tax law — outbound
German companies, family offices and funds are active worldwide. The lives of individuals based in Germany are increasingly taking place not just in one country. At the same time, international tax law is becoming increasingly complex and local tax authorities are engaged in a veritable “distribution battle” over the tax base. We face these challenges together with you.
Our Advice on Investments Abroad
One of the focal points of our work is structuring and supporting investments by German investors abroad.
Our services:
- Coordination: Close cooperation with you and your local consultants — from due diligence to contract negotiations
- All asset classes: From fund investments to real estate to forestry
- Classification: Classification of foreign companies and income
- Double Taxation: Review of double taxation treaties
- Withholding tax: In-depth experience with foreign withholding tax proceedings (in particular Canada and USA)
- Disputes: Mutual agreement and arbitration proceedings should there be double taxation
- Compliance: Preparation of a tax compliance concept for your foreign investments and assets
Transition to German tax compliance
In the end, every foreign activity must be processed and compiled for the German tax authorities. We'll take care of that.
Our services:
- Translation: Transfer of foreign accounting and accounting into German commercial and tax balance sheets
- Substance taxation: In-depth experience with the tax contribution account and Section 27 (8) German Corporate Income Tax Act
- German CFC: Calculation of CFC amounts and preparation of returns in accordance with the German Foreign Tax Act
- Reporting Requirements: Fulfilment of all notification and reporting obligations (e.g. Section 138 German Tax Act when participating in foreign companies)
- Communications: Proactive and constructive communication with the German tax authorities
Individuals in the spotlight
Individuals with nexus to several jurisdictions are increasingly the focus of the German tax authorities. We are here for you: From tax dispute proceedings to planning the move.
Our services:
- Residency: In-depth experience with all questions of tax residency
- Disputes: Representation in appeals, bin front of the tax court and the Federal Fiscal Court
- Exit Tax: Advice when changing residence abroad
- Trusts and Foundations: Classification of foreign vehicles and their distributions for German tax purposes (e.g. Liechtenstein Family Foundation, Anglo-American Trusts)
Your contacts for investments abroad
Please reach out in case you have any questions.
Marius Siemen
Marius Siemen advises on all aspects of German and international tax law. His work focuses in particular on the global investments of institutional investors and private clients across all asset classes. He has extensive experience with projects involving German investors in the United States as well as in the Asia‑Pacific region. Another key area of his practice is the representation of clients in tax disputes: from tax audits to administrative appeals and litigation, as well as the support of clients in criminal tax proceedings.
Lukas Conrady
Lukas Conrady advises investors, corporations, entrepreneurs, startups, and private clients on matters of national and international taxation. A key focus of his work lies in ongoing tax compliance—particularly the preparation of annual financial statements and tax returns, as well as the support of tax audits, including administrative appeal proceedings. He has in‑depth expertise in M&A, private equity, and real estate transactions, assisting clients with tax due diligence and the tax implementation of subsequent reorganizations. In addition, he advises on the taxation of crypto assets, including the classification and reporting of trading, staking, and lending activities.