We combine business-savvy solutions with tax-efficient structures.

Everyone wants tax optimization. But does it fit the company’s structure? What are the implications for the balance sheets? For business processes? Or for the articles of incorporation? How high are the costs?

We provide answers. Nationally and internationally. Because strategic tax planning is one of our core competencies. Optimization that isn’t “off-the-shelf”—but specifically tailored to your situation, a custom solution!

Not “tax-driven,” but tax-optimized: When developing tax strategies, we always take into account the business and legal consequences of corporate restructuring. This allows us to develop solutions that make business sense while simultaneously creating the most tax-efficient structure.

We don’t limit ourselves to expert opinions but implement our ideas together with you. Tax advisors, auditors, and attorneys all at the table. Together with you. This creates real added value for your company.

You can contact your assigned partner at WIRA at any time. He is your central point of contact for all tax-related matters, views your questions through a business lens, and coordinates global advisory services. He provides long-term support for your company and is thoroughly familiar with both the company and its tax practices.

We support you throughout the entire restructuring process with a comprehensive range of tax advisory services.

There are many reasons for changing the legal form of a business or reorganizing a corporate group. We support you throughout the entire restructuring process with a comprehensive range of tax advisory services.

Corporate structures are generally designed for the long term and should only be changed based on compelling economic arguments. For this reason, it is particularly important to monitor developments in the tax environment in Germany, the EU, and relevant third countries, and to anticipate potential changes early on. This approach expands the options for adapting corporate structures while simultaneously reducing the risk of coming into conflict with the tax principle of abuse of rights. After all, the old principle still applies here: fundamental changes, above all, require time.

We advise you on choosing the right legal structure, assess the risks, and provide certainty early on by obtaining binding rulings from the tax authorities. We also provide guidance on how you can continue to utilize losses. In addition, as part of a tax due diligence process, we assess the tax risk factors and opportunities for optimization associated with an upcoming corporate acquisition or divestiture.

Our services in detail:

Through daily communication with our clients.

A key prerequisite for tax optimization in businesses is targeted support in addressing the issues that arise on a daily basis. Competent ongoing national and international tax consulting is therefore one of our core areas of practice, within which we assist your company in developing appropriate solutions and strategies. In doing so, we promptly incorporate the constantly changing landscape of legislation and case law.

Our services also include the preparation of tax returns and tax balance sheets for companies of various legal forms. In doing so, we map out the tax optimizations developed as well as implemented restructurings and transactions through efficient processes. Of course, we also support you during tax audits and represent you in administrative and fiscal court proceedings against the tax authorities.

With the help of our international network partners, we support you in handling all tax matters, including tax filing obligations for the international entities within your corporate group.

Our range of consulting services also includes the preparation of financial accounting, annual financial statements, and reporting in accordance with national and international accounting standards, as well as the preparation of payroll accounting.

International tax consulting is also a highly personalized service.

Cross-border operations mean that companies are subject to the jurisdiction of at least two—or even more—tax authorities. This can result in double or multiple taxation. The potential causes are numerous: uncoordinated legal standards, conflicts over classification, and unfamiliar rules and deadlines, for example, pose significant risks that must be successfully managed.

However, cross-border activities also present an opportunity to leverage international tax differentials. With careful planning and attention to the various constraints and pitfalls, the tax burden can be successfully reduced through targeted international tax planning. For example, certain corporate structures or the use of selected hybrid instruments can yield tax advantages.

We assist you in selecting a location and structuring holding companies, and work with you to identify the appropriate legal form for your foreign investment—whether a permanent establishment, partnership, or corporation. We provide guidance on the tax-optimized use of low-tax jurisdictions and propose appropriate measures for cross-border profit and loss offsetting. Of course, we also handle the structuring, documentation, and defense of transfer pricing.

Take advantage of the expertise of our specialists in the areas of

WIRA supports companies through every stage of their transfer pricing planning.

Transfer pricing remains a hot topic—in Germany, since the introduction of documentation requirements, tax authorities have been closely examining other issues related to transfer pricing determination. For taxpayers, the goal is not only to avoid transfer pricing adjustments that affect income and, consequently, the tax burden. It is also essential to make optimal use of existing flexibility. Internationally operating companies recognize the need for action, which in some cases has a significant impact on the amount of group taxes.

WIRA supports companies in all phases of transfer pricing planning: from strategy development and conceptualization through to implementation.

 

Strategy and Concept Development

The interconnections of business relationships within a corporate group reflect the group management’s strategy, the complexity of business operations, and the relationship with the markets. Not only tax requirements but also internal incentive and management systems necessitate the planning, steering, and control of a group’s success factors.

Transfer pricing influences both the tax rate and the allocation of resources within the value chain. WIRA supports companies with advisory models and concepts to view transfer pricing from the perspectives of strategy, planning, value creation, and implementation.

 

Implementation

Multinational corporations face the challenge of implementing transfer pricing systems in compliance with local tax and transfer pricing regulations. A prerequisite for effective implementation is that operational management is familiar with and applies the established transfer prices. Experience, industry knowledge, and practical expertise are key factors in the successful implementation of defined business models.

Our experienced transfer pricing specialists, in collaboration with experts from our international network, ensure the highest quality in the implementation of intra-group transfer pricing systems.

 

Advance Pricing Agreements

The international tax environment increasingly offers taxpayers the opportunity to coordinate intra-group transfer pricing models with tax authorities in advance through unilateral, bilateral, and multilateral Advance Pricing Agreements (APAs) and to ensure their tax acceptance. WIRA has competent international partners who ensure the efficient implementation of APAs.

Business Models: The ongoing review of business models focuses on operational efficiency, improving cash flow, and group tax optimization. Approaches may include principal structures, shared service center models, or IP migration models. WIRA develops consulting concepts tailored to individual companies.

Industries: When designing transfer pricing systems, industry-specific characteristics must be taken into account. Influencing factors include, for example, regulatory frameworks, capital intensity, research and development activities, key account management, markets, customers, suppliers, and regional characteristics.

Tools: WIRA’s consulting concepts and tools include, in particular, project structuring, milestone concepts, project controlling, results documentation, financial analyses, documentation concepts, and transfer pricing guidelines.

Tax structuring is a critical factor in the financial success of a corporate transaction.

The success of a transaction is no accident: tax structuring is a critical factor in the financial and economic success of corporate transactions.

To this end, an overview of the tax situation as well as the opportunities and possibilities of the target company is essential. You need to know exactly where your target company stands from a tax perspective today. Based on value-oriented tax due diligence, the experts at WIRA work with you to develop customized strategies for implementing your acquisition strategy.

 

Experience in the Transaction Process – The Most Convincing Candidate Wins

In an increasingly professional and competitive environment, transactions are now routinely organized through a bidding process. In this process, the seller typically narrows down the field of potential buyers to identify their preferred candidate through several rounds of bidding. To emerge as the winner from a bidding process, the expected tax benefits (e.g., tax loss carryforwards, depreciation potential, tax credits, etc.) and tax synergies must be quantified. Tax considerations can be the decisive factor in a bidding process.

Executing a transaction requires coordinating a large number of internal and external specialists as well as processing various streams of information within a limited timeframe. In the bidding process, the timeline is dictated by the seller. The buyer cannot expect flexibility in the timeline. The organization of tax due diligence, international structuring, and tax planning calculations based on the target’s budget figures—all of this must be addressed on the first day of the transaction. Only those who have a comprehensive overview of all the facts are in a position to negotiate effectively.

 

How can we assist you with the transaction process?

Our experts will help your company organize the transaction process, avoid pitfalls, and identify opportunities. Specifically, we offer the following services:

VAT Consulting – National and International

VAT regulations are becoming increasingly complex—with new court rulings, new formalities and reporting requirements, and stricter liability and penalty provisions emerging all the time. To eliminate financial risks, such as those arising from incorrect filings, and to minimize these risks as much as possible, a proactive approach is essential.

Our experienced VAT specialists understand the unique characteristics of individual industries and develop tailored solutions to optimize VAT management within companies.

Our experts answer questions regarding national and international sales tax law. They explain how specific transactions are treated or identify the optimal structure for sales operations.

Controls can also be implemented to support risk management processes required by law or company policy. These range from risk-based checklists to simulated audits. In addition to recording and analyzing business relationships, the audits also include verification of legally required documentation obligations.

Anyone who wants to secure their assets for the long term should start thinking about succession planning early on.

The current legal landscape offers attractive opportunities for all types of assets to be transferred to the next generation with minimal tax burdens. We offer entrepreneurs and private individuals succession planning tailored to their individual needs. For family businesses in particular, the long-term survival of the company is of crucial importance. For entrepreneurs, planning certainty regarding succession is crucial. And in the private sphere as well, there are interesting opportunities to pass on assets to the next generation in a tax-optimized manner during one’s lifetime.

WIRA offers targeted and ongoing succession planning for businesses and private individuals through a trusted point of contact. With our extensive consulting experience and in-depth knowledge of the business environment, we manage the entire process surrounding generational transition. Your individual requirements are our top priority, and of course we also take special considerations into account, such as any international aspects.

In addition, we offer comprehensive support for foundations—from establishment through to foundation management.

We assist you in protecting your tax interests.

Effective and cost-efficient representation in tax litigation requires not only a high level of expertise in procedural and tax law, but also, in particular, extensive strategic experience in conducting legal disputes and a sound understanding of the client’s business interests.

Only in this way can we ensure that a dispute is not pursued for the sake of litigation, but rather that the economic implications and risks, as well as the client’s interests, remain at the center of our advice.

Our clients have access to a skilled team of attorneys and tax advisors with extensive experience in conducting tax litigation to help them assert their interests. Our litigation attorneys bring a strong understanding of business matters to the table, drawn from their many years of ongoing tax advisory work with clients. We represent our clients before all tax courts, as well as before the Federal Fiscal Court.

In the run-up to court disputes, we conduct objection proceedings and provide advice on conflicts arising during tax audits. In doing so, we always explore the possibilities for economically acceptable compromise solutions and conduct the necessary negotiations to avoid protracted disputes. Seamless, smooth collaboration between our litigation attorneys and the advisors who provide ongoing tax advice to the client is, of course, guaranteed.