Christiane Anger
Certified Tax Advisor, Lawyer, Partner, Global Employer Services
BDO has broad knowledge and experience regarding the practical application of double taxation agreements, over 90 of which Germany has agreed upon. Particularly, when it comes to deciding on the appropriate legal form for your company's international activities (foreign permanent establishment or subsidiary), it is important to avoid double taxation, optimize your tax situation and ensure that any potential tax losses suffered by permanent establishments or subsidiaries can be offset with profits in the same country or elsewhere. Intra-group holding, licensing or financing companies that have been carefully considered can lead to considerable fiscal advantages in this context. In order to avoid any unintentionally triggered taxes or the loss of losses carried forward, tax issues are often an important factor in domestic and cross-border company acquisitions and restructurings.
In Germany, a comprehensive network of anti-avoidance rules that must be considered in the context of foreign business activities has been in place for many years. Examples of such regulations include exit taxation, controlled foreign company rules for passive foreign income, anti-treaty/directive shopping rules and treaty override provisions.
