Tax expertise

“We are confident and competent when it comes to international taxation.”

Tax expertise

As a boutique provider of legal services, our law firm specializes on intellectual property and competition law. The key focus is tax law, focusing on Germany, Austria, Lichtenstein and Switzerland. In this respect, we offer our clients individual, customized tax solutions.

D-A-CH-LI & LUX

Our law firm specializes on international tax law, focusing on the countries of Germany, Austria, Switzerland, Liechtenstein and Luxembourg. We advise our clients with the structuring of private and company assets, taking the cross-border jurisprudence into account. This not only relates to the personal life planning, but also to the optimum adaptation to the tax and legal circumstances. We live in an increasingly complex world with European standards and international agreements which make financial transactions more transparent. We apply our strengths to take the requirements of both our clients, as well as the differing legislation, into account.

“The strongest relationship with a client comes about in fiscal criminal proceedings.”

Fiscal criminal law

Fiscal criminal proceedings often have a major impact on the life of an individual and their family. Everything is in play.

Our law firm specializes on fiscal criminal cases which are of a very complex and difficult nature. Fiscal criminal cases require a close and positive collaboration between the client and the attorney. In a situation which is of such a critical nature, a client needs full support: their family and social position are affected, and the press and the media are often outside their door. Professional expertise in fiscal criminal law, communication skills as well as empathy and sensitivity provide or clients with the assurance they require in such a crisis.

With our exceptional tax-related expertise in Liechtenstein, Austria, Switzerland, Germany and Luxembourg, we capture and analyze matters quickly and thoroughly. We assess tax structuring, international factors and how to approach international agreements. If required, we appoint additional international tax experts and arrive quickly at an initial estimate. On this basis, together with our clients, we develop a strategy for achieving a rapid and effective solution in a cooperative way.
In the ideal case, we also provide preventive advice. This allows us to identify and rectify uncertainties regarding fiscal criminal law in good time.

Our services

  • Support with the introduction of a tax audit
  • Support in the scope of a self-assessment or resubmission
  • Analysis and prevention of risk
  • Advice on fiscal criminal matters
  • Representation and defense during fiscal criminal proceedings

International tax law

Our law firm specializes on business and tax-related matters – at both the domestic and cross-border levels. International agreements such as TIEA, DBA, CRS, AIA, BEPS, OECD are becoming increasingly complex. We support our clients with the configuration of contracts as well as their tax planning, and accompany them in the fields of company, tax and competition law.

Focusing on the countries of Austria, Germany, Liechtenstein, Switzerland and Luxembourg, as a boutique law firm, when it comes to law and tax, we are a leader in the field of domestic and international tax law. We provide our clients with advice on international structuring, on the application of international agreements, on questions surrounding the exit tax, on succession planning and the inheritance tax arrangements as well as issues regarding asset protection.

This applies to the ideal structuring of company acquisitions just as much as it does to re-establishment and restructuring or to the configuration of funds. We support our clients in the field of private wealth management and tax planning. In addition to this, we offer our know-how in tax due-diligence audits and real estate transactions.

Our services

  • Family foundations
  • Appraisals and legal representation on matters of European tax law
  • Compiling appraisals in the areas of international tax law, the application and shaping of double taxation agreements, foreign tax law, inheritance tax law and gift tax law
  • International tax planning
  • International tax burden comparisons
  • Tax optimization of domestic and international investment decisions
  • Tax-oriented corporate financing
  • Tax advice regarding private foundations in Austria and Liechtenstein as well as other asset structures such as trusts
  • Asset and succession planning, anticipated inheritance, gifts
  • Exit and relocation planning

IP box and tax planning

The tax regime in Switzerland is currently the focus of the attention of the EU, particularly what is known as the «IP box» (Intellectual Property Box) as a special tax regime. An IP box is when a legally-permitted amount can be deducted from the sum total of the positive income from intellectual property rights. The income which is left is then taxed at the current tax rate, which results in a much lower rate of tax.

This means that a favorable taxation of income from research and development is possible. The IP box also exists in the EU member states of Belgium and Luxembourg for encouraging research and development.

With the IP box increasingly falling victim to the European prohibition of state aid, as a non-EU country, Switzerland is one of the last countries in Europe which is continuing to develop this legal institution.

We support our clients with the tax-related structuring of their intellectual property rights in the domestic and international structures of company law and with the planning of license models and license exploitation companies. We support you with setting up an IP box and with the associated tax-related and legal benefits.

Tax and succession planning

During the “Liechtenstein affair” surrounding tax avoidance with the use of Liechtenstein corporate structures in 2008, something important was neglected: objectivity. The Principality of Liechtenstein – described by many as a tax haven – offers a variety of attractive and simultaneously legal possibilities for private individuals and legal entities from abroad that allow them to enjoy tax benefits. Our expertise in the area of tax law in the D-A-CH-LI-LUX region offers a wide range of possibilities for effective tax planning through the restructuring of asset values. In this respect, succession arrangements and inheritance arrangements are also taken into account.

Our services

  • Family foundations
  • Trust solutions
  • The establishment of international holding structures
  • Company formations
  • Inheritance and succession arrangements

International agreements

Our law firm specializes on business and tax-related matters – at both the domestic and cross-border levels. International agreements such as TIEA, DBA, CRS, AIA, BEPS, OECD are becoming increasingly complex. We support our clients with the configuration of contracts as well as their tax planning, and accompany them in the fields of company, tax and competition law. We support our clients with the tax-related planning of their affairs, with the structuring of their assets as well as in the area of wealth planning.

Private clients

One of the key areas of expertise in our law firm is advising domestic and foreign family businesses as well as HNWI and UHNWI with domestic and foreign assets. In addition to company law, above all else, our key focus is on successor and asset planning as well as asset advice. To this end we apply an exceptional variety legal measures for the purpose of asset protection.

Our services

  • Advice on place of residence, distribution of assets and family domicile
  • Advice with sophisticated international inheritance and succession arrangements
  • Advice on highly complex tax and legal matters
  • Corporate structuring
  • Avoidance of double taxation, asset erosion and an excessive tax burden

Cross-border structuring

Cross-border factors make high demands on the executive management of companies. On the basis of our core strength in Austria, Liechtenstein and Switzerland, with our specific knowledge of the applicable laws, we provide support with the international and cross-border structuring of companies.

Our services

  • Company settlements
  • Foundation and organization of all corporate forms
  • Acquisition of shareholdings
  • Legal appraisals
  • Creation of holding structures
  • Cross-border restructuring
  • Cross-border outsourcing of parts of businesses
  • Relocation of corporate headquarters to Austria, Liechtenstein, Switzerland and Germany
  • Change of domicile
  • Acquisition of real estate

Exit tax

In cases of corporate restructuring and changes of domicile, the tax declaring obligations must also be taken into account – in both the country of entry and exit. It is also necessary to consider which limited tax obligations, or also, inheritance tax and gift tax obligations, continue to apply.

Our services

  • Calculations of income and dormant reserves for tax obligations
  • Declaration obligations in the country of exit and relocation
  • Advice on inheritance tax and gift tax obligations
  • Advice on specific time limits
  • Advice on the fair value of shareholdings and calculation of notional capital gains
  • Appraisals for relocation and exit arrangements
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