Tax Disputes
Tax disputes are not uncommon for corporations, family offices, funds, and private individuals. Complex tax regulations, differing legal interpretations, and the increasing intensity of audits by the Germantax authorities routinely lead to conflicts. Whether during tax audits, appeal proceedings before the tax authorities, or litigation before the fiscal courts — tax controversies are a sensitive matter that requires profound expertise.
The reasons for disputes with the tax authorities are manifold. Particularly in the case of complex structures or cross‑border matters, differing assessments are common. We support you in all phases of a tax dispute — from the initial interaction with the tax authorities through to proceedings before the fiscal courts. At every stage, we strive for communication with the tax authorities that is aligned with your interests while remaining constructive.
Support in Proceedings with the Tax Authorities
We engage with the tax authorities at an early stage on complex matters in order to provide a well‑reasoned presentation of our position. Our work is grounded in a high level of technical expertise, while always seeking pragmatic solutions.
Our services include:
- Tax audits: Representation in and management of tax audits
- Tax assessments: Review of assessment notices and audit reports
- Appeals: Representation in administrative appeal proceedings
- Litigation: Representation before the Fiscal Court and the Federal Fiscal Court
- Management: Coordination of experts and specialist advisers
- Communication: Professional and strategic communication with the tax authorities throughout the entire process
- Compliance: Review of the tax compliance framework
Support in Tax Criminal Proceedings
Tax dispute and tax criminal proceedings run in parallel in Germany but must be closely aligned in their procedural strategy. In complex cases, defence counsel regularly relies on tax experts like us.
Our services include:
- Voluntary disclosures: Preparation of voluntary tax disclosures
- Coordination: Close alignment of the tax dispute process with criminal proceedings and your defence counsel
- Expert Input: Deep subject-matter expertise for your criminal defence counsel in complex tax matters
Your contacts for tax advice regarding disputes
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.