Cross-border living situations create complex tax implications that are often not adequately addressed within a purely domestic context.
Questions around tax residency, limited and unlimited tax liability, the application of double taxation treaties and the treatment of foreign assets require a structured and informed approach.
We advise individuals who are leaving Germany, returning to Germany, or living and working across multiple jurisdictions.
Tax planning prior to a change of residence.Review and, where possible, mitigation of exit taxation under German tax law (Section 6 AStG).Determination of the relevant timing for ending unlimited tax liability and clarification of all reporting obligations.
Analysis of the tax situation upon re-establishing tax residency in Germany.Treatment of foreign income and accumulated assets.Clarification of progression rules, foreign tax credits and ongoing reporting obligations.
Determination of tax residency and habitual abode.
Application of relevant double taxation treaties.
Structuring of the individual tax situation, taking into account multiple legal systems.
Tax treatment of foreign bank accounts, portfolios, real estate and shareholdings.Review of disclosure and reporting obligations towards German tax authorities.
