Crossing boundaries.
Without stumbling on taxes.
In our globalised world, it’s becoming increasingly rare for life to stop at the national border. Whether because you’re in demand from international businesses, your employer is based abroad, your company is expanding, or a foreign-based heir is calling: in virtually every circumstance, complex issues arise concerning the taxation of the relevant money flows. Where are you taxable? How do you avoid double taxation? And what does “controlled foreign corporation (CFC) rules” actually mean? What optimisation opportunities do you have?
Based on our many years of experience as tax advisors specializing in international tax law, we are familiar with the look of uncertainty on our clients’ faces and understand just how opaque cross-border tax law can be.
We steer you through international tax regulations and clarify and identify the strategies that best suit your personal situation.
Our aim is to give you peace of mind – in your home country as well as in every participating country. And to turn international tax law into a manageable part of your life so that you can focus on what really counts: your goals and dreams – across all boundaries.
xbo.tax was founded as a strategic alliance between Hagemann Steuerberatungsgesellschaft mbH and von Arps-Aubert Steuerberatung GmbH.
Our team is made up entirely of experienced international tax advisors and international tax law practitioners and accompanies you by providing pragmatic solutions when assessing and laying out matters that comprise a foreign element.
Whether you are a foreign business operating domestically or a domestic business operating abroad, your company’s involvement in another country involves many different aspects. Whether through direct business operations, a permanent establishment, or a subsidiary—we understand the requirements and pitfalls of international business activities. From planning and establishment to restructuring and closure, we support you in optimizing the structure of your business operations both domestically and abroad. In addition to structuring advice, this includes fulfilling reporting obligations, organizing and handling accounting, as well as preparing all necessary domestic tax returns. Our tax advisors specializing in international tax law support you at every stage of your expansion—from initial planning to operational execution—and ensure the smooth management of your international activities.
Inheritances and gifts often have an international dimension: this applies not only when the decedent or heirs are resident abroad, but also between residents of the same country when foreign assets are involved. In such situations, multiple countries regularly claim the right to levy inheritance or gift tax. There is no comprehensive network of double taxation treaties in the area of inheritance and gift taxes, so there is a risk of double taxation. In addition, a cross-border transfer of shares in a corporation or of business assets may trigger so-called “exit taxation” for income tax purposes. Against this backdrop, special tax planning is required for a tax-efficient transfer of assets. Contact our tax advisors specializing in international tax law! We advise you on the tax implications of international inheritances or gifts, including structuring, avoiding double taxation, and assisting with the valuation and preparation of the necessary tax returns.
➔ More on the topic of inheritance tax abroad
Double taxation agreements (DTAs) are international treaties through which countries prevent the same taxable person from incurring multiple identical tax levies on the same income for the same period of time. The Federal Republic of Germany maintains such agreements with some 100 countries, through which tax relief claims for taxable persons can typically be derived. However, as positive as this may sound, it frequently turns out to be a complex affair in practice. Conflicts of qualification and attribution, supplementary protocols, obligations to report and subject-to-tax clauses quickly engender complex tax-related issues. We advise you on every situation by preparing expert reports, help you prepare tax returns correctly and safeguard your legal interests in Germany.
Moving abroad—even if done gradually—can have far-reaching tax consequences. Contrary to a widely held belief, this does not apply only to taxpayers who hold at least a 1 percent stake in corporations as part of their private assets and are subject to so-called exit taxation under Section 6 of the German Foreign Tax Act (AStG). Relocation can also trigger tax consequences for sole proprietors (e.g., influencers), partners in partnerships, or managing directors of corporations. What all these cases have in common is that they lead to so-called final taxation in Germany, i.e., the hidden reserves contained in the business are subject to a notional capital gains tax. Particularly complex in this context is the definition of tax departure, which can occur as a result of a legislative change (so-called “passive disentanglement”) or even gradually (shift in residency). Early tax planning for the departure by experienced tax advisors specializing in international tax law often not only helps identify and avoid risks but also, in many cases, reveals structuring options that can lead to significant tax relief. We would be happy to assist you in this regard.
➔ More on the topic of exit taxation
Where cross-border relocation is concerned, the focus of any tax advice is periodically placed on the country of departure. Taxation regulations in effect in the country of destination is a matter that taxable persons often only concern themselves with after their arrival. Tax organisation options frequently go unused as a result, especially in cases where individuals “are carrying” assets with high increases in value. Receiving expert advice in advance is especially important in this context. We help you to make full use of existing taxation options before you immigrate so that you can limit your domestic taxation to what is absolutely necessary.
Anyone drawing a German pension may well be subject to German income tax, regardless of their place of residence. Pensioners resident in Germany who receive retirement income from abroad are frequently also liable to pay taxes. We are highly specialised in the tax treatment of payments derived from foreign pension models, e.g. US 401(k) plans.
➔ More on the topic Steuer auf Rente im Ausland
Whether you are a domestic owner of foreign real estate or a foreign owner of domestic real estate, it is essential to understand the tax laws of the country where the property is located. We advise you on the tax implications of renting or selling property, taking into account the special provisions for real estate companies often included in double taxation treaties. We are also happy to assist you with the comprehensive reporting of your real estate income. Rely on the expertise of our tax advisors in international tax law when it comes to real estate!
Whether a holding company or a private or family foundation: when structuring assets, the question arises as to what tax implications arise based on the chosen structure. This is not only of significance in the context of profit tax but also inheritance and gift tax and, beyond this, also in the context of asset protection. We identify the tax implications, risks and advantages of international holding or foundation structures and assist you in their implementation.
The establishment of foreign corporations is a standard practice in international business. However, in such cases, profits are not always taxed solely in the foreign country where the corporation is resident. Under controlled foreign corporation (CFC) rules, the income of a foreign subsidiary is taxed at the level of the domestic shareholder. This is intended to prevent foreign income from being shifted to a tax- compliant corporation based in a low-tax country—which is not subject to tax in the home country—for the purpose of obtaining tax advantages. Controlled foreign corporation (CFC) rules counteract this and result in an immediate tax burden at the level of the domestic shareholder. Our international tax law specialists guide you through the complex regulations, identify risks, and highlight structuring options.
Where cross-border business operations or activities are concerned, the issue arises as to how the tax base should be split between persons known to be close associates. In such cases, observance of the arm’s length principle is the decisive factor – that is to say, from the point of view of all countries involved. One particular aspect of transfer pricing is the matter of how relocations of functions are taxed when a cross-border restructuring of the business operations occurs. We guide you through the tax risk analysis and help you comply with the arm’s length principle in an international context.
Withcross-border payments, withholding taxes play a significant role. In such cases, the government of the taxpayer’s contracting partner—who is typically resident in that country—requires the contracting partner to withhold and remit the tax directly. The payee receives only the net amount after tax. International withholding tax not only leads to potential liquidity disadvantages but also carries the risk of double taxation and liability claims. Contact our tax advisors specializing in international tax law! We advise you on options for reducing or avoiding withholding tax, on the possibilities for crediting foreign withholding taxes domestically, or handle the filing of withholding tax returns on your behalf.
What matters can we help you with?
| 2011 | Bachelor's degree in International Business Administration (B.Sc.) European University Viadrina |
| 2011 – 2012 | Research assistant at EBS University for Business and Law |
| 2012–present | Various teaching and lecturing positions, including at the Federal Finance Academy |
| 2013 | Master's degree in International Business Administration (M.Sc.) European University Viadrina |
| 2013 – 2017 | Research assistant at European University Viadrina |
| 2015 | Master's degree in European Business Law (LL.M.) European University Viadrina |
| 2016 | Doctorate (Dr. rer. pol.) European University Viadrina |
| 2017 | Appointment as tax advisor |
| 2018 – 2021 | Mazars (now: ForvisMazars), International Tax, most recently as partner |
| 2020 | Appointment as specialist advisor for international tax law |
| 2021 | Master's degree in International Tax Law (LL.M.) King's College London |
| 2022 – 2023 | Deutsche Payment A1M SE, Chief Financial Officer |
| 2023 | Founding of Hagemann Steuerberatungsgesellschaft mbH and xbo.tax GmbH |
| 1988 | Tax clerk examination |
| 1996 | Tax specialist examination |
| 1999 | Appointment as tax advisor |
| 1999 | Founding of Arps-Aubert + Partner |
| 2010 | Appointment as specialist advisor for international tax law |
| 2023 | Founding of xbo.tax GmbH |
| 2016 | Bachelor's degree in Business Administration (B.Sc.), European University Viadrina |
| 2018 | Master's degree in International Business Administration (M.Sc.), European University Viadrina |
| 2018 – 2025 | Research assistant at European University Viadrina |
| 2020 – 2024 | Lecturer at the Technical University of Applied Sciences Wildau |
| 2021 | Doctorate (Dr. rer. pol.) European University Viadrina |
| 2023 | Appointment as tax advisor |
| 2024 – present | Lecturer at the Federal Chamber of Tax Advisors for International Tax Law |
| 2004 | Tax clerk examination |
| 2010 | Tax specialist examination |
| 2021 | Appointment as tax advisor |
| 2014 | Founding of Holzinger + Migge partnership |
| 2015 | Merger with von Arps-Aubert + Partner |
| 2018 | Appointment as specialist advisor for international tax law |
| 2023 | Founding of xbo.tax GmbH |
| 1998 | Second State Examination in Law |
| 1998 – 2003 | Linklaters, Lawyer |
| 2004 | Tax advisor examination |
| 2004 – 2008 | Berlin Tax Office, Head of Department |
| 2008 – 2012 | Federal Ministry of Finance, Advisor on Double Taxation Agreements |
| 2012 – 2015 | Centre for Tax Policy and Administration at the OECD, international tax policy advisor |
| 2015 – 2018 | Federal Ministry of Finance, Corporate Tax Law Advisor |
| 2018 – 2023 | German Embassy Washington, D.C., USA, Tax Attaché |
| 2023 – 2025 | Federal Ministry of Finance, Tax Policy Advisor for Strategic Planning and International Information Exchange |
