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Tax

Providing comprehensive advice on national and international tax issues is one of CMS's core competencies. Our excellently networked tax team combines broad expertise with specialisations and many years of experience in advising companies, groups, family businesses and family offices, financial institutions, private individuals, non-profit organisations (NPOs) and the public sector at numerous locations throughout Germany and internationally. 

Our team supports you in all tax areas, including transfer pricing issues and specialised tax matters. In addition, we support our clients in tax disputes not only in the run-up to a legal dispute, but also represent them before the fiscal courts. 

Focal points

Our areas of specialisation include in particular

  • Corporate and group tax law
  • Tax support for M&A and PMI projects
  • Advice on external audits and tax disputes (in and out of court)
  • Tax compliance (prevention, defence advice and defence)
  • Real estate tax law
  • Investment tax law (fund structuring and fund investments)
  • Taxation of the digital economy (crypto and blockchain)
  • Indirect taxes (VAT, insurance tax, energy and excise duties) and customs duties
  • Tax advice in insolvency and crisis situations
  • Succession taxation and HNWIs

Future-facing - forward-looking and sustainable tax advice

The complexity of the national and global tax landscape is constantly and rapidly increasing. This presents companies, entrepreneurs and private individuals with ever new challenges. We keep an eye on all tax law developments for you and support you in reacting to them in good time with forward-looking and sustainable solutions. 

Our expertise is not limited to the legal aspects. We understand the economic environment in which our clients operate and translate our customised advice into efficient and pragmatic solutions. 

Interdisciplinary and international - customised solutions from a single source 

Almost every legal and life situation is associated with tax law issues. Our experienced teams have a trained eye for the interrelationships and work closely with all other practice areas and legal fields at CMS. 

Depending on the individual requirements of your project, we regularly work with other CMS legal disciplines, such as labour law, corporate M&A, private clients, real estate & public or restructuring and insolvency, or call in the relevant CMS experts for you. 

We also advise and coordinate international issues and cross-border mandates for you in international teams, depending on the requirements of the individual case. 

With over 500 CMS tax experts in more than 40 jurisdictions, we ensure that your interests are represented worldwide and realised from a single source.

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Erbschaftsteuerliche Optimierung
Inheritance Tax Planning
Tax efficient ways to bequeath an estate or give a lifetime gift. The German population has collectively generated huge amounts of private wealth that
Post Merger Integration
Post-merger integration (PMI)
The closing marks the end of a successful acquisition process, but not the end of the challenge of the deal itself. Expectations of a corporate transa
Umstrukturierung von Firmenstrukturen
Reorganising Company Structures
We can optimise your corporate architecture. Company structures often evolve over a long period of time and are further complicated by acquisitions. I
Steuerliche Sonderfragen
Specialist Tax Matters
Unusual requirements are our speciality. The comprehensive advisory work of CMS GmbH Steuerberatungsgesellschaft includes specialist tax matters acros
Strukturierung von Immobilieninvestments
Structuring of Real Estate Investments
We maximise the tax efficiency of your real estate investment. Property transfer tax is an important topic when investing in real estate, as is VAT in
Unternehmensnachfolge
Tax Aspects of Corporate Succession
Enabling a stress-free handover. For many medium-sized companies, it will soon be time to hand over the business to the next generation. There are var
Tax Compliance
Our experts work with you to implement regulatory requirements without creating unnecessary bureaucratic obstacles.Overview of our expertise:. Non-fin
Steuern bei M&A Transaktionen
Taxes in M&A transactions
You are planning to buy or sell a company, would like to merge or set up a joint venture? The challenges and measures which need to be considered in o

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14/03/2022
Post-Merger Integration - CMS PMI services
CMS PMI services
14/07/2020
Disclosure Requirements for Cross-border Tax Arrangements
New disclosure requirements under DAC 6 On 25 June 2018, the sixth amendment to the EU Directive on Administrative Cooperation (2011 / 16 / EU) on man­dat­ory auto­mat­ic exchange of information in the...

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12/03/2024
Multi-billion incentive programme for climate-friendly industry launched:...
Berlin – The German government is aiming to make German industry carbon-neutral by 2045. In line with this commitment, on Tuesday, 12 March 2024 the Federal Ministry for Economic Affairs and Climate Action launched the world’s first bidding process for a programme to fund climate action contracts. Based on carbon contracts for difference, these climate action contracts promote investment in climate-friendly production facilities that would not otherwise be economically viable at this point in time. The programme is primarily aimed at operators of emis­sion-in­tens­ive plants, such as in the steel, paper, chemicals, metal and glass industries. Climate action contracts provide an incentive to develop and build the required technologies and infrastructure in Germany now. This will not only avoid around 350 million tonnes of CO2 over the term of the funding programme up to 2045, but is also designed to kick-start the urgently needed market transformation while simultaneously setting new international standards for efficient, low-bureaucracy support. The climate action contracts are intended as both a key tool for climate change mitigation and to strengthen Germany as a country with a long history of industry and innovation. EUR 4 billion has been made available over a 15-year term for the initial bidding process that has now been opened. Companies that were successful in the preparatory phase in the summer of 2023 can apply to take part in the initial bidding process within the next four months. As Germany’s economics minister announced at today’s press conference, the second round of bidding will be conducted later in 2024, with EUR 19 billion available for this purpose. Two further rounds of bidding are scheduled for 2025.A CMS team headed by lead partner Dr Jürgen Frodermann advised the Federal Ministry for Economic Affairs and Climate Action on all aspects of subsidy, state aid, contract and energy law with regard to the support programme. The advice related in particular to drafting a funding policy and associated climate action contracts to be concluded between the state and companies eligible for funding. The work also included support around the notification procedure to the European Commission. In view of the pioneering nature of the funding programme, the CMS team had to deal with legal issues arising in connection with the programme in both a European and a national context, while also ensuring close alignment with the defined technical and economic objectives. The support was provided through an in­ter­dis­cip­lin­ary consortium headed by lead project manager Jülich, together with VDI/VDE Innovation + Technik and Deloitte. CMS Germany Dr Jürgen Frodermann, Lead Partner Dr Nico Hannemann, Senior Associate Dr Nora Zabel, Counsel Björn Hopen, Associate Nina Becker, Associate, all Contract Law Shaghayegh Smousavi, Partner, Energy / Regulation Dr Jakob Steiff, Partner Dr André Lippert, Partner Dr Sven Brockhoff, Counsel Dr Annchristin Streuber, As­so­ci­ate Con­stan­ze Schweidtmann, Associate, all Public Law / Subsidy Law Dr Michael Bauer, Partner Louisa Thomasberger, Associate, both State Aid Dr Martin Friedberg, Partner, TaxPress Con­tact presse@cms-hs. com
22/02/2024
Neue Chance für das Wach­stum­schan­cenge­setz
Welcome to the first 2024 podcast in the CMS To Go series "beigeSTEUERt", in which we look at the most important changes in tax legislation. Dr Martin Friedberg, Philine Lindner and Dr Hendrik Arendt present the most important new and upcoming rules around corporate tax law, including the Minimum Taxation Directive, the Financing for the Future Act (ZuFinG), the Secondary Credit Market Act (KrZwMG) and the Budget Financing Act (HFG). There is a special focus on the Growth Opportunities Act (WCG), which is aimed at making the German economy more in­vest­ment-friendly and competitive.
21/02/2024
CMS advises MVZ Laaff on sale to amedes
Stuttgart – The founder of medical laboratory MVZ Laaff, Prof. Helmut Laaff, has sold MVZ Laaff GmbH with its facilities in Freiburg, Heilbronn and Ulm to the amedes Group. amedes is a leading German lab services provider, operating a number of healthcare centres throughout Germany with different specialisations. MVZ Laaff provides services in fields of medicine including derma­to­path­o­logy, general pathology, immunohistology, molecular pathology and cytology, and is one of the leading laboratories in these specialist areas. Details of the transaction were not disclosed.A CMS team headed by lead partner Dr Christoph Lächler advised Prof. Helmut Laaff on all legal aspects of the transaction. The sale took place by way of an auction process. A particular focus of the advice was on structuring the transaction and the associated regulatory issues. CMS Germany Dr Christoph Lächler, Lead Part­ner Stefan-Ul­rich Müller, Partner Dr Jacob Siebert, Partner Viktoria Barthel, Senior Associate Tobias Kalski, Senior As­so­ci­ate An­dreas Kazmaier, Associate, all Corporate/M&A Dr Roland Wiring, Partner Dr Siham Hidar, Senior Associate, both Regulatory Dr Harald Kahlenberg, Partner Angelika Wieczorkowski, Senior Associate, both Antitrust, Competition & Trade Dr Stefan Voss, Partner Lukas Potstada, Counsel, both Real Estate Dr Martin Mohr, Partner, TaxPress Con­tact presse@cms-hs. com
21/02/2024
Die Reform der Zinsschranke
The German Parliament passed several new tax regulations at the turn of the year, including a reform of the interest barrier. The new rules, which were originally intended to be included in the Growth Opportunities Act, have now greatly extended the scope of the interest barrier. In our new podcast, Dr Hendrik Arendt and Dr Anastasia Papadelli explain the differences between the old and new rules. Have a listen.
21/02/2024
Das neue MoPeG: Welche Auswirkungen hat es auf das Steuerrecht?
On 1 January 2024, the Act to Modernise Partnership Law (MoPeG) entered into force. What is the tax law impact of the new, apparently innocuous amendments to civil law? In our latest "talkingTAX" podcast, Dr Martin Friedberg and Luise Uhl-Ludäscher deal with these questions and many other interesting issues in connection with the MoPeG. Have a listen.
20/02/2024
CMS advises HIRMER Group on sale of Travel Charme Hotels & Resorts to REWE...
Leipzig – The HIRMER Group has sold Travel Charme Hotel GmbH & Co. KG with its 13 exclusive hotels and resorts across Germany, Austria and Italy to DSR Hotel Holding GmbH. Travel Charme is regarded as an expert in the premium segment of the leisure hotel industry. It operates hotels in top locations, particularly in the Baltic region and in the Alps. The acquisition of Travel Charme boosts DSR Hotel Holding’s portfolio to a total of 35 hotels, thus expanding its market position in the German and Austrian holiday hotel sector. The transaction is currently awaiting approval from the merger control authorities. The parties agreed not to disclose further details.A CMS team headed by Dr Jochen Lux advised the HIRMER Group on all legal aspects of the sale. The company also relied on the expertise of CMS when it acquired Travel Charme in 2018. The Munich-based HIRMER Group is wholly owned by the Hirmer family. It employs some 1,800 people and operates in the fields of fashion retail, real estate management and development and in the hotel industry. DSR Hotel Holding is majority owned by DER Touristik, making it part of the REWE Group. It operates and markets a high-quality hotel portfolio comprising both growth-oriented hotel/resort brands and traditional individual hotels. CMS Germany Dr Jochen Lux, Lead Partner Dr Kevin Schmidt, Senior As­so­ci­ate Madeline Göbel, Senior As­so­ci­ate Theresa Bendix, Project Manager Nadine Fröhlich, Project Manager, all Corporate/M&A Dr Martin Mohr, Partner, Tax Dr Rolf Hempel, Partner Martin Cholewa, Counsel, both Antitrust, Competition & TradePress Con­tact presse@cms-hs. com
14/02/2024
CMS advises paint and coatings producer KANSAI HELIOS on the acquisition...
Cologne – KANSAI HELIOS has acquired the entire industrial coatings business of GREBE Holding, based in Weilburg in Hessen, Germany, which operates under the name WEILBURGER Coatings. WEILBURGER Coatings is a well-known manufacturer of industrial coatings and comprises of WEILBURGER Coatings GmbH in Weilburg and WEILBURGER Asia Limited in Hong Kong. The share purchase agreement was signed on February 9, 2024. With the acquisition, KANSAI HELIOS intends to significantly expand its strategic position as a system supplier and manufacturer of industrial coatings and extend its geographical presence internationally. The company will also gain additional expertise, distribution channels, production and storage capacities. The parties involved have agreed not to disclose further details of the transaction. An international CMS team headed by Lead Partner Klaus Jäger and Christoph Schröer provided KANSAI HELIOS with comprehensive legal advice on the acquisition. The complexity of the transaction is characterized in particular by the size of the acquired Weilburger Coatings Group, which, in addition to the German companies, includes subsidiaries in Brazil, China, France, Hong Kong, India, Italy, Turkey and the USA. In addition to the actual purchase agreements in Germany and Hong Kong, CMS drafted and negotiated numerous other contracts. In addition to CMS teams in Brazil, China, Hong Kong, Italy, Turkey, France, Serbia, Austria and the United Kingdom, the law firms MILLER & MARTIN PLLC from the USA and Vaish Associates Advocates from India also provided support. KANSAI HELIOS regularly relies on the expertise of CMS, most recently in connection with the acquisition of all shares in CWS Lackfabrik GmbH (CWS), which specializes in powder coatings and synthetic resins, including the group companies in Germany, the USA, Denmark and Poland. KANSAI HELIOS, headquartered in Vienna, is part of the Japanese KANSAI PAINT Group. The company has a history of more than 170 years and is one of the major global players in the paints and coatings market. KANSAI HELIOS designs, produces and distributes industrial coating solutions, bleaching and cleaning chemicals, materials for sticking and sealing, high-quality resins, architectural paints and refinishing coatings throughout Europe and beyond. WEILBURGER Coatings was founded in 1900 at its current headquarters in Weilburg and has group companies in Germany, Italy, France, Turkey, the USA, Brazil, India and China. With around 600 employees at seven production sites and several sales offices, the company is active worldwide and generates a turnover of around 150 million euros. CMS Germany Klaus Jäger, Lead Partner Dr Kai Wallisch, Part­ner Chris­toph Schröer, Senior Associate Dr Katharina Kapp, Associate Dr Henrik Meurer, As­so­ci­ate Domin­ic Zimmer, As­so­ci­ate Kath­rin Dengel, Associate, all Corporate/M&A Dr Björn Herbers, Partner Moritz Pottek, Counsel Dr Denis Schlimpert, Counsel Kirsten Baubkus-Gerard, Senior Associate Dr Robert Bodewig, Senior Associate David Rappenglück, Associate, all Antitrust, Competition & Trade Dr Dirk Smielick, Principal Counsel Claudia Böhmer, Counsel, both IP Dr Angela Emmert, Partner Dr Andreas Hofelich, Partner Dr Mario Brungs, Counsel Lennard Martin Lürwer, Counsel Marcel Heinen, Senior Associate, all Labor, Employment & Pensions Michael Kamps, Partner Thorsten Hemme, Principal Counsel Dr Arne Schmieke, Senior Associate, all TMC Dr Martin Friedberg, Partner, Tax law Dr André Lippert, Partner Maike Füchtmann, Senior Associate, both Real Estate & Public Dorothée Janzen, Partner Dr Philipp Rohdenburg, Counsel, both Com­mer­cial Birgit Wagner, Legal Manager Conrad Gräwe, Legal Co­ordin­at­or Steven Washington, Legal Coordinator Anke Clippingdale, Senior Legal Specialist Edris Trabzadah, Senior Legal Specialist Faraz Ahmad, Legal Specialist Sofia Schreiner, Legal Spe­cial­ist Al­ex­an­der Stadahl, Legal Specialist, all Smart Operations CMS Beijing Falk Licht­en­stein Roxy Meng CMS Milan Daniela Murer Alessandra Cuni CMS Rome Fabrizio Spagnolo CMS Istanbul Döne Yalçın Merve Akkuş CMS Paris Thomas Hains Marion Berberian CMS Belgrade Maja Stepanović CMS Vienna Dr Dieter Zandler CMS London Russell Hoare Melanie Lane Focaccia Amaral L S Advogados, Brazil in association with CMS Renata Homem de Melo Fontes Carla Anastácio Lau, Horton & Wise LLP, Hong Kong in association with CMS Shirley Lau Albert Jok MILLER & MARTIN PLLC, USA Joe DeLisle Vaish Associates Advocates, India Shrinivas SankaranPress Con­tact presse@cms-hs. com
13/02/2024
CMS advises on sale of flexis AG to Blue Yonder
Stuttgart – The shareholders of flexis AG, a flexible, innovative software technology provider specializing in production optimization and transportation planning and execution, have sold all shares to Blue Yonder, a leading supply chain solutions provider. flexis AG specializes in the development of software-based technologies aimed at optimizing supply chain management (including ordering, production, planning and execution of transports). With the acquisition, Blue Yonder expands its portfolio with a stable customer base in the automotive and OEM sector and its offering to companies with highly configurable products and an extensive network of suppliers. The combined technologies of the two companies are intended to improve production planning, order fulfilment and supply chain performance for customers and thus offer added value. The parties involved have agreed not to disclose further details of the transaction.A CMS team headed by partner Dr Heiko Wiechers and Dr Andreas Lohbeck advised the shareholders of flexis AG on all legal aspects of this transaction that underlines again the team's strength in cross-border deals in the technology sector. flexis AG, headquartered in Stuttgart, specializes in flexible, innovative software for optimizing supply chain planning and execution. With seven locations worldwide, flexis AG can look back on more than 25 years of company history. Blue Yonder, based in Scottsdale, Arizona, U.S., is global market leader in digital supply chain trans­form­a­tions.  CMS Germany Dr Heiko Wiechers, Partner, Co-Lead Dr Andreas Lohbeck, Principal Counsel, Co-Lead Julia Fünfgeld, Senior Associate, all Corporate/M&A Dr Markus Kaulartz, Partner, TMC Dr Martin Mohr, Partner, Tax law  Birgit Wagner, Legal Manager Lisa Mattmann, Senior Legal Specialist, both Smart OperationsPress Con­tact presse@cms-hs. com
05/02/2024
CMS advises Savills Investment Management on sale of Hamburg office property...
Stuttgart – Savills Investment Management (Savills IM) has sold a 16,000 square metre office property in Hamburg to the Cells Group. The Cells Group is acquiring the Atrium Office building at Glock­en­gießer­wall 21/22 in Hamburg on behalf of Kuwait’s sovereign wealth fund. Located between the main railway station and the city centre, Atrium Office comprises a her­it­age-pro­tec­ted building constructed in 1908 and an annex that was refurbished in the 1990s. Up to now, the property was part of special fund Savills IM Real Invest 1. The parties have scheduled the transfer of rights and liabilities for the first quarter of 2024.A CMS team headed by partner Dr Volker Zerr advised Savills IM on all legal and tax aspects of the transaction. The CMS team regularly advises Savills on real estate transactions, with a recent example being the sale of a superstore in Berlin-Spandau on behalf of the European Retail Fund (ERF). CMS Germany Dr Volker Zerr, Lead Partner Sandra Scheib, Coun­sel Jac­queline Terhöven, Counsel, all Real Estate & Public Tobias Schneider, Partner, TaxPress Con­tact presse@cms-hs. com
26/01/2024
CMS advises on sale and leaseback of high-tech site near Stuttgart
Stuttgart – CMS has advised a technology service provider on the sale of its Flugfeld-Allee 12 site in Sindelfingen near Stuttgart to an institutional investor. A lease with a fixed term of 15 years was then concluded with the seller for the whole area, with options to extend the lease once for five years and once for three years.A CMS team led by Dr Volker Zerr advised on all legal and tax aspects of the sale and leaseback transaction. Constructed in 2015, the property at Flugfeld-Allee 12 is located on a site of around 30,000 square metres in the Flugfeld Böblin­gen/Sindelfin­gen mixed residential and commercial area. It comprises several buildings: 9,703 square metres of office space, an 8,081 square metre workshop fitted out for research and development, 1,628 square metres for storage and a canteen covering 1,039 square metres. CMS Germany Dr Volker Zerr, Lead Partner Sandra Scheib, Counsel Dr Kathrin Groß, Counsel Michelle Bucher, Senior Associate, all Real Estate & Public Dr Tobias Grau, Partner Susanne Waldhans, Senior Associate, both Corporate/M&A Dr Andreas Grunert, Principal Counsel, Banking, Finance & Insurance Tobias Schneider, Partner, TaxPress Con­tact presse@cms-hs. com
16/01/2024
CMS advises family owners of precision machine manufacturer Benzinger on...
Stuttgart – The families that own Pforzheim-based Carl Benzinger GmbH have sold a majority interest to Syngroh Capital GmbH, the investment firm set up by the entrepreneurial Klaus Grohe family. The current owners, the Jehle families, will retain a significant minority stake in Carl Benzinger GmbH and continue to manage the company operationally. The majority stake taken by Syngroh Capital will provide Benzinger with a long-term entrepreneurial partner who will contribute to the engineering company’s growth. Details of the transaction were not disclosed.A CMS team headed by lead partner Dr Claus-Peter Fabian advised the family owners of Carl Benzinger GmbH on all legal aspects of the transaction. Carl Benziger GmbH is a leading manufacturer of high-precision lathes and milling machines for a variety of industries, including the watchmaking and jewellery industries as well as sectors such as optics, precision mechanics, medical, dental, electrical and control technology, fluid and bearing technology, the automotive supply industry and aerospace. Benzinger offers everything from a single source – from engineering and building or setting up the machine tools through to after-sales service. The company’s customers include both local firms and world-famous luxury brands. CMS Germany Dr Claus-Peter Fabian, Lead Part­ner Kath­ar­ina Ivic, Senior Associate Julia Fünfgeld, Senior Associate Dr Maximilian Eitelbuß, Senior Associate, all Corporate/M&A Dr Martin Mohr, Partner Tobias Wacker, Associate, both Tax Dr Michael Rein, Principal Counsel, Labor, Employment & Pensions Dr Michael Kraus, Partner, TMC Dr Stefan Voß, Partner Lukas Potstada, Counsel, both Real Estate & Public Thomas Fröhlich, Counsel, IP Lisa Mattmann, Senior Legal Specialist, Smart OperationsPress Con­tact presse@cms-hs. com
16/01/2024
CMS advises listed mobility solutions specialist Össur on acquisition of...
Frankfurt/Main – Össur, Nasdaq Copenhagen listed leading global provider of innovative mobility solutions, acquired all shares of privately owned Fior & Gentz, a Germany based leading European manufacturer of lower limb neuro orthotic components. Fior & Gentz develops and distributes knee and ankle orthotic joints to create innovative custom-made orthotic solutions for patients with gait impairments due to neurological conditions. The acquisition of Fior & Gentz represents an attractive opportunity for Össur to enter the fast-growing neuro orthotics market. The transaction volume amounts to around EUR 100 million plus an earn-out of up to EUR 20 million. The payment consists of cash as well as of newly issued, listed shares of Icelandic Össur hf. to the sellers of Fior & Gentz. An international CMS team led by Dr Heike Wagner and Dr Tobias Kilian advised Össur comprehensively on all legal aspects also in connection with this transaction. CMS Germany Dr Heike Wagner, Partner Dr Tobias Kilian, Of Counsel, both Lead Dr Reiner Thieme, As­so­ci­ate Nath­alie Amrhen, Associate, all Corporate / M&A Jörg Schrade, Partner Eduard Kosavtsev, Senior Associate, both Tax Dr Roland Wiring, Partner Dr Siham Hidar, Senior Associate  Noah Rodenkirchen, Associate, all Regulatory & Lifesciences Dr Stefan Lehr, Partner, Antitrust, Competition & Trade Dr Dirk Smielick, Principal Counsel, IP Prof Dr Malte Grützmacher, Partner, IT Dr Boris Alles, Partner Dela Herr, Associate, both Labor, Employment & Pensions  Dr Franz Maurer, Counsel Wiebke Westermann, Associate, both Real Estate & Public CMS Netherlands Roman Tarlavski, Part­ner Mar­cel­lina Rietvelt, Associate, both Corporate / M&A Martijn van der Bie, Partner Gieneke van Nierop, Counsel, both Corporate / Notaries CMS Norway Nicolas Jorn Brunet, Partner Tuva Svare, Associate, both Corporate / M&A Henrik Nordling, Partner, Antitrust, Competition & TradePress Con­tact presse@cms-hs. com