THINK GLOBALLY, ACT TAX-OPTIMALLY
WELL ADVISED WORLDWIDE
WORLDWIDE INCOME.EMIGRATION.IMMIGRATION.
I want to become a clientINTERNATIONAL TAX LAW
Beyond national borders.
Mastering tax challenges together
International tax questions don't only affect large corporations or wealthy investors. Even owning a holiday home in Spain, a bank account in Switzerland or a stake in a foreign company can have tax consequences.
While you change your centre of life, tax obligations often remain – and not only in Germany. Different tax systems, double taxation treaties and reporting obligations make international tax planning complex.
I support you in avoiding cross-border tax traps, reducing double taxation and making the best use of your tax options – for a worry-free future beyond national borders.
The world is becoming ever more connected – people live, work and invest across borders. But while your centre of life changes, tax obligations often remain complex.
I help you keep an overview and structure your tax burden optimally – whether you are moving abroad, returning to Germany or investing internationally.
Worldwide income
Germany taxes the worldwide income of persons resident in Germany – regardless of whether the income comes from Germany, Switzerland or the USA. Without smart tax planning this can lead to unnecessary burdens.
Your tax benefits at a glance:
- Avoiding double taxation:
By reviewing international tax treaties or national credit rules, I make sure you do not have to pay tax in two countries on the same income. - Optimal structuring of international income:
Whether rental income from abroad, international employment income or capital investments – I develop a tax-optimised strategy to reduce your tax burden. - Meeting filing obligations:
International income entails extensive filing obligations. Avoid tax pitfalls so that all relevant information is correctly taken into account.
Emigration
Anyone leaving Germany often triggers complex tax consequences – such as exit taxation or filing obligations abroad.
How you benefit tax-wise:
- Avoiding or optimising exit taxation:
I check whether and how hidden reserves (e.g. in business holdings) can be transferred tax-neutrally on emigration or the tax burden can be spread out. - Minimising tax risks on emigration:
Avoiding double taxation, reviewing taxing rights under international treaties and national special rules. - Obligations when unlimited tax liability ends:
I support you with the proper tax deregistration in Germany and the structuring of your last German tax year.
Immigration
Moving to Germany automatically has tax consequences, in particular regarding unlimited tax liability and the inclusion of worldwide income.
Your added value at a glance:
- Avoiding double taxation on immigration:
I check for you how foreign income is to be treated in Germany and make sure international tax treaties are used optimally for you. - Declaring income and assets correctly:
Support with the complete and correct reporting of foreign income on immigration. - Strategic structuring of the move-in date:
By optimally planning the timing of your move and the asset structure, tax advantages can be used and unnecessary (additional) burdens avoided.
I help you keep an overview and structure your tax burden optimally – whether you are moving abroad, returning to Germany or investing internationally.
Why work with me?
KNOW-HOW IN
INTERNATIONAL TAX LAW
Individual solutions instead of standard advice – every international tax situation is unique. I offer tailor-made advice for your specific needs. Every international tax case is unique. Special needs require special advice.
Global expertise – implemented locally. Through my experience with international tax matters I make sure you are optimally positioned for tax purposes worldwide.
Legal certainty and tax optimisation – combine meeting all tax obligations with reducing your tax burden at the same time.
Book an appointment
One click to your individual tax advice
In the initial consultation we take the time to understand your concerns and discuss first ideas for your tax optimisation.
- Non-binding initial consultation – a clear start, without risk
- Discreet & GDPR-compliant contact
- Direct contact with the tax advisor – no assistant loops
- Quick, uncomplicated appointment booking
- Advice that works across generations and lasts long term
How would you like to start?
FREQUENTLY ASKED QUESTIONS
What is meant by international tax law?
International tax law deals with the taxation of cross-border matters, such as foreign income, double taxation treaties and international corporate structures.
When do I need a tax advisor with expertise in international tax law?
If you earn income abroad, own assets abroad or plan to expand internationally, specialised advice is essential.
What is a double taxation treaty (DTT) and how does it affect my tax liability?
A double taxation treaty is an international agreement between two states that regulates which country has the right to tax certain income and to what extent.
Not all double taxation treaties avoid double taxation completely – they regulate whether and how it is avoided or mitigated (e.g. exemption or credit method).
The aim is to avoid, or at least mitigate, double taxation of the same income – usually by exemption or by crediting the foreign tax.
How is foreign income taxed in Germany?
The taxation of foreign income depends on the relevant double taxation treaty (DTT). In many cases it is either exempt in Germany (with progression clause) or the tax paid abroad is credited against German income tax.
What matters is whether the income falls under the worldwide income principle (unlimited tax liability) or only domestic income is relevant (limited tax liability).
What tax obligations do I have when moving abroad?
Moving abroad can have considerable tax consequences – for both entrepreneurs and employees.
For entrepreneurs or shareholders, the following applies in particular:
The so-called exit taxation (§ 6 AStG) applies when an individual with a substantial shareholding in a corporation (at least 1%) moves abroad. In this case a notional disposal gain is taxed, even if no actual sale takes place.
In certain cases the tax can be deferred (e.g. when moving to an EU/EEA country).
For employees, the following points are particularly relevant in the year of departure:
In the year of departure there is unlimited tax liability up to the day of the move and subsequently, where applicable, limited tax liability for German income (e.g. if work continues for the German employer).
For cross-border activity in the year of departure, special allocation rules under § 50d EStG apply, in particular for salaries subject to wage tax. Income is often allocated pro rata temporis to Germany and the new state of residence.
Double taxation treaties (DTT) regulate which state has the right to tax. What matters, among other things, is where the centre of vital interests is located.
Note: even hidden taxable benefits such as severance pay or stock options can be allocated proportionately to Germany if they relate to the period before departure.
How are foreign dividends taxed in Germany?
If the source country levies withholding tax, it can be credited against German flat-rate withholding tax depending on the DTT – however, only up to the German tax burden (generally 25% plus solidarity surcharge).
What do I need to consider when setting up a subsidiary abroad?
Both the tax rules of the target country and German regulations must be taken into account. Careful planning is essential to avoid tax disadvantages.
What reporting obligations exist for assets abroad?
In particular, accounts and securities accounts abroad are subject to notification and filing obligations under § 138 (2) AO. Capital income and rental income must also be fully stated in the tax return.
How can I avoid double taxation?
By applying DTTs and targeted tax planning, double taxation can be avoided or reduced.
What are the tax implications of income from property abroad?
Income from foreign property can be taxable both abroad and in Germany.
As a rule, the right to tax belongs to the state where the property is located (Art. 6 OECD Model Convention). In Germany, exemption with progression clause then usually applies.
How is foreign pension income taxed in Germany?
Foreign pensions can be taxable in Germany. The exact taxation depends on the respective pension and on the relevant double taxation treaty.
For foreign statutory pensions, the paying-state principle (taxation in the source state) often applies. Private pensions are frequently subject to the residence principle. The relevant DTT is decisive.
What tax obligations do I have when posted abroad?
When posted abroad for work, tax obligations can arise in both the home country and the host country. Early advice is essential.
How is foreign investment income taxed in Germany?
Foreign investment income is subject to capital gains tax in Germany. Credit is given under § 34c EStG in conjunction with the relevant DTT, provided the withholding tax is proven.
What tax aspects should be considered with international inheritances?
International inheritances can be taxable in several countries. Double taxation treaties and national laws regulate the exact taxation.