Prevent & eliminate
double taxation.
Germany & Switzerland.

If Germany and Switzerland tax the same profit, double taxation follows. We coordinate across Germany and Switzerland without handover between adviser teams.

Focus: tax audits, cross-border adjustments and double taxation defence with a Germany–Switzerland nexus. No general tax services.

What this looks like in practice

Double taxation arises when two states claim the same profit but there is no coordinated position. We align tax law and procedures in Germany and Switzerland under one lead.

What we do

We take mandates where double taxation is imminent or already present. A common trigger is a German tax audit adjustment that requires a corresponding correction in Switzerland.

Typical triggers
  • Transfer pricing adjustment involving a Swiss group entity
  • Permanent establishment or profit allocation dispute
  • Estimated assessments or hidden profit distributions with cross-border effects
  • Parallel proceedings or inconsistent qualification
If more than one state is involved, you need one coherent line.

How we work

Legal architecture

As lawyers and advisers we design the procedural strategy across interfaces: facts, qualification under German and Swiss law and the defence or correction line are built as one coherent structure for both states.

Germany & Switzerland

Cross-border under one lead. Argumentation, procedure and implementation are aligned across Germany and Switzerland – without handover between adviser teams.

Multidisciplinary

Tax law, procedural law and international qualification converge in one team. No handover between specialists – one line, jointly led.

Published expertise

Ongoing authorship on tax audits, mutual agreement procedures and cross-border profit allocation. The line we run for you is the line we also write about.

Why oi.tax

Integrated across both legal systems

Cross-border matters often fail where German and Swiss law are not coordinated in one consistent approach.

One lead contact

Cross-border cases are typically split across different adviser teams. Multiple responsibilities create handover risk and inconsistent positions.

One coherent line

In cross-border proceedings, the line must not get lost between responsible parties. You receive one coordinated lead across both states.

One line.
One lead contact.
Germany & Switzerland.

Is my case a fit?

Typically a fit
  • A cross-border tax audit is upcoming or already ongoing
  • Profit adjustment in Germany with effects in Switzerland
  • Profit adjustment in Switzerland with effects in Germany
  • Transfer pricing or PE is qualified differently
  • A corresponding correction between DE and CH is foreseeable
Usually not
  • Purely domestic matters without cross-border nexus
  • Cases without Germany or Switzerland nexus
  • General tax services without audit context
  • Pure documentation without dispute relevance

Contact

oi.tax is the entry point for cross-border matters. We intake requests in Zurich, classify the matter and involve Hamburg if German proceedings are affected.

Zurich office

International qualification and tax adjustments. Transfer pricing, corresponding corrections, Germany–Switzerland coordination and mutual agreement procedures.

+41 44 585 11 85

Hamburg office

German proceedings support. Tax audits, objections and tax court litigation, procedural and enforcement topics.

+49 40 49 20 93 43

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