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Dimitar Hristov

Partner
Besides his high understanding of complex tax questions he does a phenomenal job of reducing complexity and working with people.
Client, Chambers Europe 2022
About

Dimitar Hristov heads the Tax practice in DLA Piper’s Vienna office.

As an attorney-at-law with completed tax advisor education he has vast experience in international tax law, corporate taxation, tax planning and tax advice in connection with international restructurings and reorganizations, mergers and acquisitions, corporate finance transactions, venture capital and private equity structures.

Dimitar advises HNWI and their Family Offices especially from Germany and whole Eastern Europe in estate, gift and succession tax planning, usage of foundations and trusts for tax purposes and the migration of High Net Worth Individuals from and to Austria.

Prior to his cooperation with DLA Piper Dimitar was tax manager and tax director with a leading tax advisory and auditing firm with activities in the CEE-region.

His doctor thesis: “Business taxation of the liquidation of corporations”, was published in 2011 by Lexis Nexis.

Professional QualificationsRechtsanwalt registered with Rechtsanwaltskammer Wien

EXPERIENCE

  • Advising a Spanish bank and its Austrian subsidiary on the securitization of Austrian loans of the borrowers and transfer to Ireland.
  • Advising a leading gas export company in connection with the tax due-diligence and the tax structure of the acquisition of Centrex Europe Energy & Gas AG. The obligations of the seller under the sale and purchase agreement have been secured by the surety issued by the affiliate of the seller.
  • Tax related restructuring advice to a large bank based in South America regarding the transfer of several foreign subsidiaries to Portugal and Brazil.
  • Advising a US-based global leader in connected car technology and audio innovations on a fiscal criminal matter involving the incorrect taxation of employee options.
  • Advising an Austrian construction company, a subsidiary of an international steel company, on various tax aspects related to the reorganization and recapitalization of the company.
  • Advising a trailer leasing company headquartered in the Netherlands on a securitization project involving various European locations including unified post-payments and the set-up of a payment-system.
  • Advising a US-based technology company on the tax implications regarding the acquisition of an Austrian entity.
  • Advising an Anglo-South African international banking and wealth management group and an Austrian special bank for the financing of infrastructure and energy projects in Europe on a facility agreement regarding a cross-border loan.
  • Advising an Austrian laquers and coatings manufacturer on financial criminal law issues regarding a fiscal criminal proceeding with reference to a research bonus.
  • Advising an Austrian construction company on the new setting-up of the financial personnel management of the company in a new holding-structure and the transfer from Ukraine to Austria, including the setting up of a employment compliance system.
  • Advising Meritz Securities in the context of the sale of Hilton Parkview (Austrian "Deal of the Year 2019") on both the financing and the sale on the buyer's side and on the transaction itself, including advice on the tax structuring.
  • Advising the Ministry for Energy and Water of a South-Asian country in the set-up of a tax treaty regarding the allocation of the taxation rights concerning an international pipeline trough three countries in the region.
  • Advising an Italy-based manufacturer of lighting and lighting products, while being faced with the allegation of having paid too little tax and therefore an extra amount of EUR 5 million has been claimed.
  • Advising a Luxembourg based real estate development company on the tax structuring concerning the sale of a well-known hotel in the Vienna City.
  • Advising a global tax services company with reference to the refund of capital gains tax based on a recent ECJ Judgment.
Languages
  • German
  • English
  • Bulgarian
  • Russian
Education
  • University of Vienna, Mag. iur., 2005
  • Vienna University of Economics and Business Administration, Dr. iur., 2010
  • Dimitar Hristov has completed an Austrian tax advisor education/exam

Awards

  • "He is really experienced in this area, with a lot of technical knowledge of the regulation" Client, Chambers Europe, 2021
  • "A client states that he 'seeks for an individual solution rather than propose a ready product.‘ " Legal 500, 2020

 

Publications

  • Hristov/Zeitlinger, Russian residence rules in connection with the application of Double Tax Treaties, Trust & Trustees, 2017 (Oxford University Press), in press.
  • Hristov/Zeitlinger, Russia’s CFC-rules: the latest developments and issues with foundations of a legal character, Trust & Trustees, 2016 (Oxford University Press), 616 ff.
  • Hristov, Kommentar zu § 19 und 20 Körperschaftsteuergesetz, in Lang/Schuch/Staringer (Hrsg), Kommentar zum österreichischen Körperschaftsteuergesetz, 2016, 2. Auflage.
  • Hristov, Steuerrechtlicher Teil zu Verschmelzungen, in Aburumieh/Adensamer/Foglar-Deinhardstein, Praxisleitfaden Verschmelzung, 2015, 349 ff.

Seminars

  • Speaker at private and public institutions on several tax topics (e.g.: the STEP organization, the Austrian ÖPWZ/Union of Austrian Financial Planners).

Prior Experience

Prior to joining DLA Piper, Dr. Hristov was a Manager (Tax) and Director (Tax) at a well-known CEE-wide tax advisory and accounting firm.

Lecturer

  • Lecturer for Austrian Tax Law at the Vienna University of Economics and Business Administration
  • Lecturer for International Restructuring Tax Law at the Vienna University of Economics and Business Administration postgraduate MBL/MLS program “Business Law”
  • Lecturer for Austrian Tax Law at the Vienna University, postgraduate LLM program “Tax Law and Accounting (Prof. Kirchmayr)”
  • Lecturer for European and International Tax Law at the Vienna University, postgraduate LLM program “European and International Business Law (Prof. Fina)”

Memberships And Affiliations

  • Austrian Bulgarian Business Club
  • Austrian Russian Friendship Society

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