Wolfgang ReulSenior Associate
I help clients to design and implement solid tax structures to streamline tax audits and subsequent procedures.
Wolfgang Reul is a German qualified tax advisor, with more than five years' experience advising multinationals and medium-sized businesses in international (inter alia transfer pricing) and German tax matters.
Wolfgang's practice focuses on the design and implementation as well as the defense of group tax structures. He's helped clients to cope with controversy situations with local tax administrations.
Wolfgang advises clients in many sectors, notably in the fields of Financial Services, Industrials, Real Estate, Technology, Insurance, Consumer Goods, Food and Retail.
He's particularly experienced in (judicial and extrajudicial) appeal proceedings and mutual agreement / arbitration proceedings.
Having gained significant experience in the field of transfer pricing, international tax and real estate transfer tax, he provides holistic advice to multinational clients covering the full range of tax services including subjects such as global mobility and wage tax, real estate transfer tax, withholding tax and VAT.
- Conceptual design and implementation of a transfer pricing model for a medium-sized group.
- National implementation of an Advance Pricing Agreement (APA) between the Federal Republic of Germany and the Republic of Finland on a trademark license and centralized services.
- Re-assessment of the profit allocation to permanent establishments across 27 jurisdictions including tax return corrections according to Sec. 153 AO (German Fiscal Code) for a German based group in the construction industry.
- Initiating and advising on corresponding adjustments within the meaning of Art. 9 (2) OECD-MTC in Germany and other EU countries and thus avoiding a lengthy mutual agreement procedure.
- Defense of agreed terms of intra-group loans in the context of a tax audit.
- Tax audit preparation for US multinational in relation to multi-billion USD IP-onshoring including global value chain and DEMPE analyses and re-assessment of intercompany debt financing arrangements.
- Transfer pricing advice on the restructuring of a financial institution in respect of disentangling complex series of financial transactions involving insolvency law considerations in Germany, Luxembourg, UK and the US.
- Valuation of real estate for RETT purposes.
- Johannes Gutenberg-University Mainz, Master of Science, Master in International Economics and Public Policy, 2016
- Johannes Gutenberg-University Mainz, Bachelor of Science Management and Economics, 2013
- German-Source IP Taxation: Developments and Concerns, in: Tax Notes International Volume 101, No. 9, March 1, 2021, p. 1163-1168 (with Raimund Behnes, Dr. Ulf Andresen and Thore Holtrichter)
- Germany's Source Taxation Conundrum, in: Tax Notes International Volume 100, No. 10, December 7, 2020, p. 1325-1327 (with Dr. Ulf Andresen and Thore Holtrichter)
- Extraterritoriale Einkünfteabgrenzung, Bestimmung des Anteils der Einkünfte iSd § 49 Abs. 1 Nr. 2 Buchst. f Doppelbuchst. aa EStG aus Vermietungen und Verpachtungen zwischen zwei ausländischen verbundenen Unternehmen, in: Internationales Steuerrecht 2020, p. 833-840 (with Thomas Gericke, Dr. Ulf Andresen and Thore Holtrichter)
- 2016-19; Consultant/Senior Consultant/Manager, Transfer Pricing, Frankfurt based Big Four