Pioneers in Tax - WTS in Germany
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International Tax & Permanent Establishments (ITP)

The operational functions of multinational companies (R&D, production, sales, services, etc.) are usually spread across multiple locations around the world. This presents considerable challenges to tax departments, because foreign tax regulations often differ significantly from local tax legislation.

The ITP experts at WTS specialise in tax support for project work abroad. This is often required for mechanical and systems engineering, the IT industry, the service sector, as well as many other industries. All the while, the fiscal framework conditions in the project country and the ever-evolving international environment are key complexity drivers. Even at the tender stage of a project, there are special tax regulations that must be taken into account, which in turn influence the structure, calculation and realisation of the project.

Specifically, our ITP experts advise on the selection of organisational structures in the conflicting area between foreign subsidiaries and permanent establishments (PEs). In doing so, the recognition, registration and processing involved with PEs - also permanent representatives according to BEPS - is a constant focus of our work.

In addition, we help companies to fiscally optimise their business models abroad (sales agents, commissionaires, dependent agents). Our range of services include tax planning and, structuring cross-border contractual agreements within the group. Furthermore, due to the growing importance of digitalisation, we are closely monitoring the current developments regarding what would constitute a “virtual permanent establishment” and its tax implications. We also offer tax advisory on foreign inbound permanent establishments within Germany.

At WTS, we provide companies with customised, practical and pragmatic solutions across all key legal areas during their projects. Many of our ITP experts are native speakers and highly familiar with the fiscal particularities of individual regions and countries, all the while operating and advising in the German time zone and with an understanding of German tax law.

Due to our special employee structure, which is made up of numerous corporate practices, we understand companies from an insider’s perspective. This makes us the ideal tax partner for interface and process consulting, such as with transfer pricing, VAT, customs and global expatriate services. The ITP experts work very closely together with specialists in these fields as part of integrated project teams.

Main Contact
Ulrike Schellert
Managing Partner
Certified Tax Consultant
> View Profile
Main Contact
Martin Loibl
> View Profile
Newsletter ITP #1/2019
Changes in international tax law and country-specific developments with respect to the taxation of permanent establishments in 10 selected countries
View publication

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