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Ask us directlyTax Services Across Germany
What these engagements turn on
Departure year return for a family that moved from Ontario
A family left Ontario for Germany in the spring and assumed their Canadian filing obligations ended with the move. We prepared the departure year return on the basis that Canadian residency ceased on a stated date, dealt with the deemed disposition that arises on ceasing residence, and set out which assets were excluded from it. The house they kept was let, so we put the rental income onto the non-resident basis it belonged on and arranged the reporting that goes with that. The engagement produced a filed departure return, a written residency position, and a rental arrangement the payer could operate.
Catch-up filings for an American resident in Germany for years
An American who had lived in Germany for many years had never filed a United States return, having assumed that paying German tax was the end of the matter. We established which years were actually open, reconstructed the income from German payslips and bank statements, converted each year on a documented basis, and prepared the returns together with the separate reporting of foreign financial accounts. Credit for the German tax paid removed most of the liability. The engagement produced a complete set of filed years, the account reporting that belongs with them, and a written explanation of how the position was reached.
Correcting withholding on a Canadian pension paid to Germany
A retired teacher living in Germany was having Canadian tax taken at source from a pension and could not tell whether the amount was right. We identified the type of payment, checked it against the treaty category it fell into, and established the rate that should apply to a resident of Germany rather than the default non-resident rate. Where too much had been taken we filed to recover it, and we gave the payer the residency evidence needed so that later payments would be withheld correctly. The engagement produced a corrected withholding arrangement and a recovery claim for the earlier years.
First Canadian filings for the subsidiary of a German parent
A manufacturer in Germany incorporated a Canadian subsidiary to hold inventory and employ local staff, and reached its first year end without knowing what had to be filed. We set the corporate filing calendar, registered the company for the sales tax it was required to collect, prepared the first corporate return with the intercompany charges from the parent properly described, and documented the basis for those charges. The engagement produced a first filed corporate year, a registration in place from the correct date, and a written note the parent’s German adviser could rely on.
A residency analysis for a researcher on a German fellowship
A doctoral researcher moved to Germany on a fellowship while keeping a Canadian bank account, a car and a room in the family home. The question was whether Canadian residency had been severed at all. We worked through the ties on both sides, concluded that Canadian residency continued for the period in question, and filed on that basis with credit for the German tax paid on the fellowship. The engagement produced a residency analysis in writing, returns filed consistently with it, and a clear statement of what would have to change before a different conclusion could be reached.
Estate of a Canadian who died while resident in Germany
A Canadian who had settled in Germany died holding property in both countries, and the executors did not know which authority had the first claim. We dealt with the Canadian side: the final return for the year of death, the reporting of the deemed disposition that arises on death, and the clearance the executors needed before distributing anything. We set out in writing which assets fell within the Canadian charge and which did not, so the German adviser could complete the estate work without guessing. The engagement produced a filed final return, a clearance application, and an asset by asset position.
Three Countries in One File and Two Treaties That Disagree
Income sourced in one country, paid to a resident of a second, held through an entity in a third: three bilateral treaties, no three-way rule. The analysis works out which pair governs each flow, and whether the middle entity is entitled to anything at all.
Read how this one runsAn Assignee Paid at Home and Taxable Away
Where pay stays on the home payroll but the tax arises elsewhere, a shadow run reports the second country's liability without duplicating the payment. Setting it up correctly is what keeps both sides reconcilable.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
Strategy and compliance for income, assets and families spread across borders.
Industries & Client Types We Serve Worldwide
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Software revenue crosses borders by default — sourcing rules, withholding on licence-like payments and IP location decide the effective rate.
Software revenue is rarely taxed where the team sits. Licence, subscription and service income are characterised differently by each side, and the answer decides withholding at source, treaty relief and whether a foreign customer creates a taxable presence at all — questions that are cheap to settle before the contract and expensive afterwards.
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
