Investment Consulting:

iSP Global Tax offers your client broad tax consulting services with regard to your client’s investment activities abroad. We support you and your client together with our network of experienced colleagues from the specific foreign country. We initiate the contact, coordinate the project and check in close alignment with our colleagues abroad the tax consequences in Germany and abroad. Based on your client’s market entry strategy we provide advice on the following matters:

• choice of location
• choice of a suitable corporate form including entrepreneurial cooperation such as Joint Ventures and the setting up of Permanent Establishments abroad and the cross-border income allocation
• safeguarding of public subsidies  
• tax optimised finance structure
• tax registrations
• opening of bank accounts
• drafting and conclusion of necessary contracts
• tax planning for expatriates assigned abroad
• tax planning for owners / CEOs who are resident in Germany
• monitoring the implementation of an internal and external accounting system

iSP Global Tax also offers tax consulting services referring to your client’s expansion plans abroad. Based on your client’s 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 of the tax optimal funding

Restructuring Consulting:

The increasing market globalisation permanently challenges international acting companies to adapt their legal group structure to the company's performance and to execute restructuring projects affecting their presence in foreign countries 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 foreign network partners we can offer you support in the following areas:

• tax optimised change of corporate forms of foreign companies. For example, demergers or cross-border mergers
• asset transfers
• tax optimised structure for company sales and their valuation
• consulting with regard to functional relocations of functions or moving in taxation

iSP Global Tax offers an indicative first assessment of the tax circumstances abroad, coordinates the project and arranges the collaboration with foreign colleagues. In parallel we check the tax consequences of the foreign transaction steps with regard to German Taxation.

Tax Optimisation:

After a successful set-up or expansion we can accompany your client on their way to optimise the chosen legal structure. Particularly the reduction of tax quotas, the selection 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 your client the following services in this context:

• with regard to group-internal cross-border transactions we can support your client in determining 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 client’s 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 Price Adjustments
• check of Withholding Tax reductions or exemptions for dividends, licence and interest payments, if necessary by optimising the holding structure
• check if Permanent Establishments are set up, and clarifying legal qualification conflicts with foreign consultants
• development of an aligned profit split system for Permanent Establishments according to the German Tax Authorities Administrative Guidelines, including support for the preparation of all necessary documentation in this context

After a successful set-up/expansion/restructuring/tax optimisation of your client’s business activity we can additionally offer your client 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:

• (support in) 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 abroad.

For self-employed individuals, we can offer your client support in:

• planning and tax optimization services referring 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 foreign tax declaration obligations by mediation of foreign tax consultants
• questions referring to the foundation of a potential service Permanent Establishment abroad

For employed individuals

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 appointed lawyer:
  • drafting of employment contracts and deployment agreements according to Labour Law
  • legal questions with regard to temporary workers
  • advice with regard to Labour Management Regulations and Collective Labour Agreements in an international context
• 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 in cooperation with foreign legal and tax consultants:
  • 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 optimised management assignments

Advice relating to your Client’s Moving Out:

iSP Global Tax can assist your client with regard to your client’s creation of a permanent residence abroad in relation to the following questions:

• tax planning and optimisation in Income tax, Inheritance and other capital-based tax matters. For example, the creation of business assets and use of foreign holding companies
  • determination of the location for your prospective permanent residence, taking tax advantages into account
  • checking requirements for a moving out process
  • evaluation of all national and foreign tax risks
  • planning of your stay abroad
  • checking all other relevant factors, including tax options for a return to Germany
• succession planning and coordination in cooperation with a separately appointed lawyer for inheritance tax legislation
• creation of dual residences with regard to possible income double taxations and the use of Inheritance Tax Double Tax Treaties

Property Investment Advice:

• tax planning and optimisation in Income Tax, Inheritance and other capital-based tax matters especially with regard to the release of hidden reserves of
  • shares in national capital companies and business partnerships
  • German real estate