International Tax

Our services

• Advice on the relative merits of subsidiaries and permanent establishments in other countries
• Advice on the selection of sites for investment in other countries in the context of local tax concessions
• Optimization of participation structures in respect of
  • exemption from dividend earnings/gains on disposal
  • deduction of operating expenditure/utilization of losses in the group
  • avoiding additional taxation under the German Foreign Tax Act (AStG)
  • reducing withholding tax
  • thin capitalization
• Consulting on the acquisition of foreign participations (in collaboration with our M&A team)
• Consulting on sales structures: trader on own account/broker/agent
• Tax planning in relation to the structuring of cross-border intercompany activities in the group (in collaboration with our Transfer Pricing team)
• Project consulting for plant engineering and construction
  • Calculation of taxes on offer submission
  • Project structuring with respect to the establishment or avoidance of permanent establishments
  • Profit splitting between parent company and permanent establishments for both international and domestic tax purposes
  • Avoiding foreign sales tax as a cost factor
  • Tax consulting on project delegations in respect of both company taxation and the taxation of the expatriates (in collaboration with our Global Expatriate Services team)
• Withholding tax advice and compliance
  • Tax consulting for technology agreements (for example advice on the contractual tax clause)
  • Reduction/avoidance of withholding taxes in connection with dual taxation agreements and/or EU directives
  • Obtaining exemption certificates/preparing tax registrations

General starting point

The operational areas of your company (R&D, production, sales, etc.) have come to be spread across a large number of domestic and international sites. Avoiding unnecessary taxes as a cost factor and reducing the tax load is of central importance to your company.

Alongside German domestic tax law and the provisions of the double taxation conventions, European law (including EU directives and case law from the European Court of Justice) is exerting ever more influence on the treatment for tax purposes of cross-border affairs.

A strong team of specialists is essential for effective consulting in the increasingly complex area of international tax law. WTS’s INT Division offers you just such a team.

How and why WTS?

Our team, unlike its equivalents in many consulting companies, counts among its members a large number of specialists with the extensive hands-on experience that can only be gained in corporate tax departments. This background ensures that our people really understand your concerns and expectations through and through. We plan out our practical solutions for you in a succinct and readily comprehensible form, and draw on our ample corporate experience to provide concrete proposals for action to help you implement our structuring concepts.

The dynamic growth enjoyed by WTS AG has in no way restricted our freedom to discuss and tackle issues across departmental boundaries. Our INT team, for example, works closely with WTS specialists in M&A, Transfer Pricing, VAT and Expatriate Services. The interdependencies that exist between these different disciplines are often underestimated, but thanks to our integrated approach we are able to avoid the kind of uncoordinated actions (Company VAT and tax on earnings on the one hand versus the personal income tax of the employee on the other, for instance) that can lead to the inadvertent and undesirable creation of permanent establishments.

We have a particularly strong vein of expertise in the area of order-related project taxation (for example in plant engineering and construction) abroad. Our in-house experience acquired from plant and mechanical engineering companies makes us an ideal point of contact on tax matters for your sales departments and your company’s business administration units for project work.

We place special value on international strengths when selecting members for our team. Our multilingual employees in Munich and Düsseldorf (English, French, Spanish, Italian, Dutch, Polish, Russian, Ukrainian and Chinese) specialize by region, with each having a thorough knowledge of the tax regulations of his or her ‘patch’. This means that our people are able to provide you with preliminary information from Germany and structure your enquiries efficiently before they are submitted to our international cooperative partners. We thus reduce your need to seek advice in the country concerned to save you both time and money.

We pursue our activities internationally through a hand-picked network, the WTS Alliance, and proven cooperative partners in a host of other countries. All of our international partners have been carefully selected to ensure they measure up to the WTS standard for quality, international experience, speed of response and terms and conditions.

We have considerable experience in project coordination involving the management of an established team of foreign consultants. Even in cases where your concerns encompass a range of countries, we can ensure that you receive all of the advice you need from your usual central contacts in Munich and Düsseldorf.