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.
We defend, we correct, we represent.
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
An adjustment in one state triggers an obligation in the other — that obligation does not enforce itself. Bilateral correction coordination between Germany and Switzerland is the standalone core service: regardless of whether the trigger is a transfer pricing adjustment, a permanent establishment dispute or a hidden profit distribution.
What we do
We take mandates where double taxation is imminent or already present. The product is always the same: bilateral correction coordination DE↔CH — an adjustment in one state requires the corresponding correction in the other, and that correction must be actively enforced. This is not a by-product of other advisory work. It is the standalone service.
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
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.
Bilateral correction coordination
A correction in one state only achieves its purpose if it triggers the right response in the other. We coordinate corresponding corrections, secondary adjustments and procedural steps across both states — consistently, under one lead, without handover risk.
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 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
- Tax audit or proceedings in Switzerland — even without a German nexus
- A Swiss holding, service company or IP structure is under scrutiny from German, Austrian, French, Italian, Dutch or Polish tax authorities — and the profit allocation to Switzerland is at risk of reversal
Usually not
- Purely domestic matters without cross-border nexus
- Cases without any 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.
Hamburg office
German proceedings support. Tax audits, objections and tax court litigation, procedural and enforcement topics.
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