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Tax Scenario

Corporate Tax

Strategic tax services for corporations: enhancing compliance and providing individual tax advice in a rapidly evolving digital landscape. Below you'll find some frequent scenarios, providing you with some first guidance.

I am the managing director of a foreign corporation (e.g. an Estonian OÜ - established under the e-residency program). Are there any tax implications in Germany?

  • If you're a German resident acting as a managing director of a foreign corporation, the corporation may be subject to tax liability in Germany on income sourced within Germany.
  • Further, it is very likely that a so-called management permanent establishment is at hand in Germany resulting in additional exposure of the foreign entity's to German corporate- and trade tax.

We want to incorporate a management incentive program. What should we know?

  • Participants in management incentive programs may face income tax on benefits received (i.e. payments in kind). The timing and valuation of these benefits can affect tax liability.
  • In Germany, such benefits are often treated as additional salary and taxed accordingly. There are certain structures that provide for a tax-free setup of such programs, e.g. under the newly introduced ESOP rules under section 19a of the German income tax code (§ 19a EStG).

We are a non-German corporation and want to set up a German subsidiary. What do we need to do?

  • A German subsidiary is fully liable for taxes in Germany on its worldwide income. This includes corporate income tax, trade tax, and VAT on its operations.
  • Detailed compliance with local tax and corporate law is essential for operating a subsidiary in Germany.
  • At first it should be reviewed what legal form is benefitting your business needs and strategy.
  • Secondly, a German attorney and notary must be engaged and the tax structure should be looked at (e.g. how you may tax efficiently repatriate profits to your holding entity).

I am looking for tax planning & tax structuring. Can you assist?

  • Having all the numbers at hand it is crucial for us to understand where your business is heading to.
  • While combining accounting and tax data with a company's strategy and taking into account tax implications we can be your sparring partner when it comes to tax-efficient structures.
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Corporate Request Form.

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