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Optimizing the corporate structure
from a legal, business, and tax perspective, structuring of corporations, partnerships, hybrid entities and joint ventures, Restructuring Tax Act
International Tax Law
, Mitigation of double taxation, taxation of permanent establishments, mitigation of withholding taxes, relocation, double or no tax residency, immigration and exit-taxation, Tax Treaty Law, BEPS, Multilateral Instrument, ATAD, CFC-rules, GAAR, CCTB, DAC-6 notifications
M&A
, Strategy consulting, deal structuring, due diligence, valuation, spa-negotiations, pre- and post deal structuring, deal-financing, management participation and incentive schemes
Structuring of management functions, incl supervisory and advisory boards, planning of estate and business
succession
from a heuristic perspective, foundations, trusts and family offices
Structuring and optimization of
contributions and distributions
, dealing with the contributions tax account and distribution blockers, structuring of acquisition cost.
Optimization of
financing structure
and financing mix regarding equity, debt, mezzanine and hybrid financing, interest caps, withholding taxes, capital taxes, mitigation of capital export regulations, cash notification rules and the beneficial owner transparency regulations
Transfer Pricing
, structuring of intercompany transactions, valuation of value chain components, determination of transfer pricing method, calculation of transfer prices
Tax Controlling
, tax risk management, tax checks, internal audit, tax audits, tax rulings, advance pricing agreements, appeals, mutual agreement procedures
External Tax Communication
, CbC-reporting, sustainability reporting,
Business Reorganisation
from a management, business and tax perspective, reorganization, refinancing, and asset protection