oi.tax
since 2009 · Hamburg & Zurich

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.
With practice and professional admission across both jurisdictions, we run the defence as one coordinated strategy.

Typical triggers
  • Transfer pricing adjustment involving a Swiss group entity
  • Permanent establishment dispute or profit allocation challenge
  • 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

Coordinated procedural strategy

We structure the facts, determine the qualification under German and Swiss law,
and set the defence or correction line for both states.
The result is a position that remains consistent across jurisdictions.

Hamburg & Zurich

We work integrated across both legal systems, Germany & Switzerland.
Argumentation, procedure and implementation are aligned end to end.

Hamburg office

German proceedings: tax audits, objections and tax court litigation.
For cross-border matters, Zurich leads the international coordination;
Hamburg contributes German audit and litigation know-how.

Zurich office

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

Who we are

oi.tax is a specialised unit for cross-border audit, dispute and adjustment matters with a Germany or Switzerland nexus.

Focus areas
  • Preventing and eliminating double taxation
  • Cross-border tax adjustments and corresponding corrections under one lead
  • Transfer pricing in tax audits and disputes, including mutual agreement procedures
  • Permanent establishments and profit allocation in tax audits
  • Tax dispute strategy and dispute prevention, escalation architecture

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 different responsible parties.
You receive one coordinated lead across Germany & Switzerland.

One line.
One lead contact.
Germany & Switzerland.

Integrated across Germany & Switzerland, without handover between adviser teams.

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 permanent establishment is qualified differently
  • A corresponding correction between Germany and Switzerland is required or foreseeable
Usually not
  • Purely domestic matters without cross-border nexus
  • Cases without Germany or Switzerland nexus
  • General tax services without audit or adjustment context
  • Pure documentation without dispute or procedural 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.

Email: Zurich office

Hamburg office

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

German proceedings: via Zurich intake.