Tax structuring and planning

Tax structuring and planning alternatives have to be taken into consideration in the process of current tax filings and during special situations such as the incorporation, restructuring and liquidation of businesses and during transactions. Moreover, the ever changing rules of tax law, administrative decrees or case law of the Federal Fiscal Court always entail a requirement for action.

Based on our specialisation we are in a position to deliver expedient custom-tailored solutions for clients wherever there is a need for structuring and planning. In this connection, we place strong emphasis on a thorough analysis of the specific situation, of the alternatives for action coming into consideration and the exact implementation of the envisaged structuring measures. We are aware that tax optimisation is not an end in itself but has to be reasonable also from the perspective of business management.

Overview of our services

  • Tax advice and support during business reorganisation (merger, change of legal form, division, spin-off, divided inheritance, constituting or avoiding the split of a unitary business etc.)
  • Analysis of the facts of a situation with regard to tax optimization opportunities and suggesting new organizational structures
  • Tax optimization of real estate investments (for example application of the extended trade tax relief, saving real estate transfer tax (RETT) with RETT blockers, use of reserves according to Sec. 6b Income tax Act [Einkommensteuergesetz – EStG]
  • Tax advice during transactions (choice of the appropriate transaction structure and review/design of contracts)
  • Reviewing and designing contracts under tax aspects (corporate contracts, articles of association, partnership agreements, executive employment contracts etc.)
  • Advice for setting up, refinancing and liquidating companies (legal and tax aspects for choosing an adequate legal form, comparison of tax burdens, treatment of reorganization-related profits etc.)
  • Obtaining planning certainty for intended measures by obtaining advanced rulings from the fiscal authorities