Investment Consulting:

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

• choice of location
• choice of a suitable corporate organization including entrepreneurial cooperation such as Joint Ventures and the setting up of Permanent Establishments in Germany and the 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 the expansion plans of your client 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 optimal funding
• execution of tax induced evaluations of companies and intangibles

Restructuring  Consulting:

Increasing market globalisation challenges foreign internationally operating companies permanently  to adapt their legal group structure to the company's performance and to execute restructuring projects affecting their presence in Germany as well. Additionally, mergers, the acquisition of companies or focussing on their own core competence 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 forms of German companies. For example, conversion from corporation to partnership and vice versa, mergers, demergers, hive-downs of assets into corporations respectively of single assets into partnership, share-for-share exchanges
• 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 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
• identification 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 offer you advice on the following matters:

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

In  the case of claims during tax audits we can offer you the following services:

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

Consulting for Self-Employed and Employed Individuals

iSP Global Tax offers you advice with regard to tax planning questions and the fulfilment of tax obligations in Germany.

As self-employed person we can offer you support in:

• planning and tax optimisation services relating to your client’s German business, for example as an artist or sportsperson. For a tax optimal contract design, we will work together with a separately appointed legal counsel
• fulfilment of German tax declaration obligations
• questions referring to the (unintentional) setting up of a potential Service Permanent Establishment in Germany

iSP Global Tax can assist your client and their employer in the following tax matters:                                        

• coordination of the following services which are provided in cooperation with a separately mandated lawyer:
  • drafting of employment contracts and deployment agreements in accordance with German Labour Law
  • legal questions relating to temporary employees
  • advice on Labour Management Regulations and Collective Labour Agreements in an international context
• support with regard to Visa applications
• counselling and support with regard to the design of employee assignments in line with Social Insurance Regulations
• application of Social Security Certificates in Germany and abroad
• in relation to intercompany deployments:
  • planning and execution services
  • documentation
  • evaluation of Transfer Pricing Risks with regard to cost allocations, transfer of intangible assets (e.g. know-how) and Permanent Establishment questions
  • coordination of Advanced Pricing Agreements, Mutual Agreements Proceedings or (European) Arbitration Proceedings
  • tax optimized management assignments
  • benchmarking of management salaries for Transfer Pricing purposes

Advice relating to Your Client’s Moving In:

iSP Global Tax can assist Your Client with the creation of or change to a permanent residence in Germany in relation to the following questions:

• tax planning and optimisation in Income Tax, Inheritance and other capital-based tax matters, e.g. creation of business assets and use of foreign holding companies
• succession planning and coordination in cooperation with a separately appointed lawyer in accordance with German Inheritance Tax legislation
• creation of dual residences with regard to possible income double taxations and the use of Inheritance Tax Double Tax Treaties
• advice in connection with applicable Property Tax

Property Investment Advice:

• tax planning and optimisation in Income Tax, Inheritance and other capital-based tax matters
• support in fulfilling German tax declaration obligations, checking of tax assessment notices, participation in tax audits and conduct of appeals against Tax Offices and claims before the Fiscal Courts