SPARK

When things get complicated, experience counts

Tax matters can pose significant risks to your business – especially when you operate across borders or make major corporate decisions. That’s when it pays to have a specialist by your side who deals with these questions every day.

Your Specialist for International Tax Services

Cross-border activities and international taxation are part of our everyday work. From expert tax opinions to practical implementation, we specialise in foreign income, withholding taxes and international corporate structures.
 
Make use of our experience: for a clear assessment of the legal situation, pragmatic solutions and strategic foresight.

Let's discuss your case

Foreign income is often taxed twice – once in the source country where it arises, and again in your country of residence. We help you make use of double taxation agreements to avoid this, either by exempting foreign income or by crediting taxes already paid abroad. We are also experienced in dealing with specific cases such as income earned by academics, artists or public officials.

Are you temporarily working in Germany or planning to move abroad soon? We clarify your tax residency and help you avoid exit taxation.

Whether it’s a short workation or a long-term assignment, employees – and often business owners themselves – now work abroad. We help you avoid triggering additional tax obligations in another country and clarify questions around payroll tax and social security.

Anyone leaving Germany permanently risks being subject to high exit taxation. We show you planning options to avoid or defer these tax burdens.

Interest payments, licence fees, artist fees or dividend distributions are often subject to withholding tax. We assist you in obtaining an exemption from withholding or reclaiming the tax paid.

Whether a film set, development centre or sales office – once your business operates abroad, it typically establishes a permanent establishment there. The (sometimes even deemed) profits must then be taxed abroad. We help determine these profits accurately, identify planning opportunities, set appropriate transfer prices and review function profiles and relocations.

When your suppliers or clients are based abroad or when services are provided electronically or via digital platforms, VAT matters can quickly become complex. We provide certainty for your pricing and contractual negotiations through a reliable assessment of VAT obligations and explain the special procedures that must be observed in reporting.

As a business, you are entitled to VAT reimbursements on goods and services consumed. To ensure you receive refunds for VAT paid abroad, we handle the refund process for you – with the Federal Central Tax Office (BZSt) and the respective foreign tax authorities.

Whether for cooperation or expansion – subsidiaries can complement your parent company and offer great structuring potential for tax optimisation. We develop cross-border structures that minimise your tax burden and compliance costs, and that make efficient use of financing and licensing arrangements while protecting you from controlled foreign company taxation.

Once you operate across borders, the tax authorities will apply much higher documentation standards – with high potential penalties for non-compliance. We help you stay fully prepared and well-documented for any tax audit.

We are happy to support international clients with all ongoing tax obligations arising from cross-border activities.

International Clients

Your Specialist for Acquisitions & Restructurings

Formation, restructuring, exit – few company decisions carry greater tax implications. From strategic planning to implementation, we specialise in developing optimal tax structures, providing tax support for business acquisitions and advising on tax aspects of corporate reorganisations.
 
Make use of our experience: for a holistic optimisation of your tax structure, forward-looking planning and legally compliant implementation.

Let's discuss your case

Few decisions have greater consequences for your business than choosing the right legal form. We show you which options best suit your goals and consider both you as a private individual and your company as one tax entity, whether at the founding stage, during expansions or when preparing for an exit.

Businesses are constantly evolving, whether through changes in legal form, mergers, new shareholders or the division of business areas. We support you through these major decisions, ensure tax compliance and show you ways to achieve tax-neutral transformations that anticipate future developments. We preserve your company’s capital and position you securely for the future.

When you acquire a company, all its hidden tax risks transfer to you. We support you during negotiations with careful tax due diligence, quantify potential risks and advise on appropriate indemnity and liability clauses in the purchase agreement.

Whether for sale negotiations or shareholder buyouts, a professional valuation of your company by an independent expert is often essential. We use recognised methods to derive a reliable valuation based on your actual financial data.

International connections within your business offer not only commercial opportunities but also attractive tax structuring options. We develop cross-border structures that optimise your tax burden and compliance effort, align with your business objectives and make efficient use of financing or licensing arrangements while protecting you from controlled foreign company taxation.

The legal situation is not always clear-cut, which often creates significant tax risks. We help you achieve legal certainty through binding tax rulings, mutual agreements or advance confirmations from the tax authorities.

We are happy to support companies in the creative industries with all tax compliance obligations arising from new or reorganised corporate structures.

Creative Industries