Tax audit and tax dispute
Tax audits and other tax proceedings can lead to protracted conflict situations with the tax authorities, which can also escalate into criminal tax proceedings. In addition to finding an appropriate solution to the tax dispute, the avoidance of unjustified tax claims (possibly with an impact on future assessment periods) is a key objective. With regard to the foresighted avoidance of criminal tax law scenarios, communication in ongoing taxation proceedings (so-called co-operation) is of great importance. Last but not least, functioning tax compliance is also essential for managing directors and board members in order to limit liability.
Our tax litigation and tax compliance services include:
- Conducting tax due diligence for complex investment structures and strategies
- Optimizing investments through domestic and international investment vehicles, including securitization solutions
- Structuring national and international funds, particularly in real estate and alternative investments
- Structuring profit participation rights, bonds, and other hybrid investment alternatives
- Advising on the implementation of management participation programs and carried interest structures
- Guiding domestic funds to avoid tax disadvantages under new investment tax regulations
- Assisting companies in reviewing add-back criteria per Section 7 AStG and determining relevant amounts
- Advising natural persons on changing their place of residence abroad, taking into account exit taxation in accordance with Section 6 AStG, since 2025 also for holding investment funds
- Support with external tax audits
- Delivering expert opinions on tax-oriented capital investments and financing structures
- Securing binding rulings from tax authorities
- Obtaining negative confirmations from the Federal Financial Supervisory Authority (BaFin) to avoid unauthorized investment transactions in alternative investments
Track Record
Tax disputes and tax compliance:
- Represented managers in discussions with tax authorities regarding the tax treatment of exit proceeds from management participation schemes
- Advised private individuals on tax disclosures involving large assets and complex matters, including various proceedings under § 153 AO and § 369 et seq. AO
- Provided business management support, including handling criminal tax proceedings involving the application of the Foreign Tax Act
- Assisted a medium-sized company in the documentation and declaration of international employee postings
- Supported a private individual during a tax audit concerning capital income and white accounting of non-transparent funds
- Guided a private individual in disclosing capital income and managing the downstream transfer of assets
- Secured binding information on tax retroactivity in cases involving civil law reversal of transactions with undesirable consequences
- Set up tax compliance and declaration protocols for a multi-level partnership group
- Development of a tax compliance management system for medium-sized companies with purely national business and international business (often focussing on VAT compliance)
- Oversaw a tax audit, including criminal tax proceedings, related to the tax assessment of foreign asset-managing corporations
- Support for tax audits of a property group
- Support for external tax audits by the BZSt (Federal Central Tax Office)
- Fiscal court proceedings for purchase price allocation of developed properties
- Fiscal court proceedings due to failure to recognise (economic) capital losses for tax purposes
- Tax court proceedings on car use in connection with VAT and hidden profit distributions VAT and hidden profit distributions
- Tax court proceedings Interpretation of the concept of a permanent establishment
Your challenge is our priority
In a non-binding consultation, we’ll work together to explore the best options for you and how we can assist.
