Investment Consulting:

iSP Global Tax offers you broad tax consulting services with regard to your investment activities in Germany. We support you and (if the case may be) your consultants together with our network of experienced colleagues. Based on your market entry strategy, we provide advice on the following matters:

• choice of location
• choice of a suitable corporate organisation, including entrepreneurial cooperation such as Joint Ventures and the setting up of Permanent Establishments in Germany and cross-border income allocation
• tax optimised finance structures
• tax registrations
• opening of bank accounts
• drafting and conclusion of necessary contracts
• tax planning for expatriates assigned to Germany
• tax planning for owners / CEOs who are not resident in Germany
• monitoring the implementation of an internal and external accounting system

iSP Global Tax also offers tax consulting services referring to your expansion plans in Germany. Based on your expansion strategy we can support you as follows:

• in the case of a company acquisition we execute the necessary tax due diligence to evaluate tax and tax related legal risks
• implementation of tax optimised holding structures
• in the case of Joint Ventures or other forms of cooperation, we can advise you how to arrange a tax optimised organisation
• guidance on tax optimized funding
• execution of tax induced evaluations of companies and intangible assets

Restructuring Consulting:

Increasing market globalisation permanently challenges foreign internationally operating companies to adapt their legal group structure to the company's development, and to execute restructuring projects affecting their presence in Germany. Additionally, mergers, the acquisition of companies, or focussing on their own core competence, all require the investment or disinvestment of company assets. These projects help you to achieve strategic aims such as growth or the increase of profitability or the company value.

iSP Global Tax is there to assist you to organise such transaction processes. In close cooperation with our network partners, we can offer you support in the following areas:

• tax optimised change of corporate organisation of German companies. For example, conversion from corporation to partnership and vice versa, mergers, demergers, hive-downs of assets into corporations, or of single assets into partnership, share-for-share liquidation of German companies
• asset transfers
• tax optimised structure for company sales and their valuation
• consulting with regard to the cross-border relocation of functions or moving in taxation

Tax Optimisation:

After a successful set-up or expansion, we can assist you on your way to tax optimise your chosen legal structure. Notably, the reduction of tax quotas, the allocation and assignment of group-internal services or deliveries and the fulfilment of tax compliance guidelines require more and more attention. In collaboration with our foreign network partners, we can offer you the following services in this context:

• with regard to group-internal cross-border transactions, we can support you in determining your group internal Transfer Prices from a tax perspective, including Value Added Taxes (VAT) and Accounting
• adaptation, testing and optimising the implemented Transfer Pricing System, including Transfer Pricing Documentation (Master and Local File)
• design of internationally aligned Transfer Pricing Models tailored to your company
• determination of adequate spreads for licences and interest rates
• initiation of Mutual Agreement Proceedings, (European) Arbitration Proceedings and Advanced Pricing Agreements
• expert's and second opinions
• VAT check with regard to group internal and group external cross-border business transactions
• check of proper invoicing and declaration, especially with regard to (retroactive) Transfer Pricing Adjustments

After a successful set-up/expansion/restructuring/tax optimisation of your German business activity we can additionally advise on the following matters:

• analysis, planning and documentation of group-internal transactions
• fulfilment of ongoing tax obligations (accounting, balancing, tax declaration)
• ongoing tax planning

If you meet with objections during tax audits, we can offer you the following services:

• tax audits defence
• execution of appeals against Tax Office or Fiscal Court decisions