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Dr Konrad Rohde LL.M.

Partner
Konrad Rohde was excellent. He knows his area of law well and applies a complex area in a constructive and easy to understand manner.
Legal 500 Germany 2022
About

Dr Konrad Rohde advises on all aspects of domestic and international tax law. His clients include German and international corporations and partnerships. He focuses on transactional tax, M&A transactions, conversions, reorganisations, restructurings and international tax structuring. He also provides advice on tax audits and tax litigation, as well as general advice on corporate tax.

His transactional tax practice focuses on investments and divestments of investors, tax structuring for initiators of tax optimised investments and advice on the set-up and implementation of tax concepts. Konrad also has profound experience in advising non-profit organizations.

In tax audits, Konrad negotiates with the tax authorities and represents clients in administrative and legal proceedings.

Professional QualificationsRechtsanwalt admitted with Rechtsanwaltskammer Frankfurt am MainSteuerberater registered with Steuerberaterkammer Hessen

EXPERIENCE

  • Advising global engine manufacturer on sale of subsidiary.
  • Advising James Hardie Industries plc on the acquisition of XI (DL) Holdings GmbH and its German and international subsidiary company (including Fermacell GmbH).
  • Advising the DAX company, BASF, on the planned acquisition of the integrated global Polyamides business of Solvay.
  • Advising Qualcomm Incorporated regarding an agreement with TDK Corporation (Tokio) for setting up a joint venture.
  • Advising a leading supply chain software provider on its acquisition of a German software developer, included provided ongoing tax advice on intellectual property structuring between Germany and the US, post-acquisition transfer and structuring, and post-acquisition tax issues.
  • Advising Lone star on tax aspects for the acquisition of a majority stake in ISARIA Wohnbau AG.
  • Advising tech companies in handling administrative proceedings with German tax authorities regarding IP registered in German books and registers.
  • Advising a large private equity fund over years in acquisition and divestitures of various kinds of assets.
  • Representing a non-German investment fund in tax court proceedings and in front of the European Court of Justice relating to German investment taxation issues.
  • Representing a German manufacturer in tax audit and tax court proceedings regarding interest deduction limitation rules.
  • Representing a US multi-national comprehensively vis-à-vis the German tax authorities, inter alia, in real estate transfer tax issues, pension issues, tax audit questions.
  • Advising a US tech company in various acquisitions of national and international targets.
Education
  • Universities of Passau, Göttingen and Heidelberg, Law
  • Northwestern University School of Law Chicago, LL.M.
  • University of Osnabrück, Ph.D.

Awards

  • JUVE Handbook Tax 2022: Frequently recommended for group taxes: tax structuring and project advice as well as for transaction taxes - tax contract structuring and tax structuring advice
  • Legal 500 Germany 2023: Recommended for tax law; “is very thorough and attentive in his approach, providing pragmatic solutions to problems at hand.”
  • Handelsblatt in cooperation with Best Lawyers 2023/2024: Recommended for tax law

Publications

  • 'Tax liability of foreign funds from 2004 to 2017 before the ECJ’ Börsen-Zeitung, October 2020
  • ‘Tax trap international licence agreements’ Börsen-Zeitung, May 2020
  • 'More complex than a floppy disk' Frankfurter Allgemeine Zeitung from 25.05.2016, page 18 (with Dr. Raimund Behnes)
  • 'Using data base applications via the internet – liability of the licensee for withholding taxes of the foreign licensor' Computer und Recht from May 15, 2016, page 281 (with Dr. Raimund Behnes and Judith Nink)
  • 'No right to elect cash accounting for shareholder of foreign partnership', Steuerrecht Kurzgefasst 15/2015 from August 05, 2015, page 320
  • 'Consequences of the decision of the ECJ of October 9, 2014 van Caster, Deutsches Steuerrecht, edition 50/14 from December 12, 2014, page 2494
  • "Foreign Foundations: Sec. 15 of the Foreign Transactions Tax Act and Amendments – Criminal Tax Aspects (Fiduciary Foundations) – Donations to Foreign Institutions", BetriebsBerater 2014, 1495 (with Dr. Björn Enders)
  • Will the German interest deduction limitation rules be found unconstitutional? Action steps for taxpayers as the courts decide, 29 Apr 2014
  • "Request of a transfer pricing documentation is in line with EU law" (Federal Tax Court from April 10, 2013, I R 45/11) - comment, Internationales Steuerrecht, edition-no. 18 from September 19, 2013, page 717
  • "Separate and consistent income statement in the participation of a foreign family foundation" (Federal Tax Court from May 13, 2013, I R 39/11) - comment, Internationales Steuerrecht, edition-no. 15 from August 1, 2013, page 581 
  • "Asset management of gold by company in London" (Hessian Tax Court from November 11, 2012, 11 K 3175/09, rkr.) - comment, Internationales Steuerrecht, edition-no. 4 from February 21, 2013 page 157 
  • "Does the taxation of non-transparent fund limit the free movement of capital?" (Fiscal Court Düsseldorf from May 3, 2012, 16 K 3383/10 F) - comment, Internationales Steuerrecht, edition no. 17 from September 6, 2012, page 663 (with Dr. Steffen Neumann) 
  • "Taxation of income from non-transparent public-investment fund for private investors," Finanz-Rundschau, edition-no. 6 from March 03, 2012 (with Dr. Steffen Neumann) 
  • "Permissibility of profit according to § 4 section 3 of the Income Tax Act for purposes of progressive taxation" (Hessian Tax Court from October 29, 2010, 11 V 252/10, unchallengeable after para 128 sec. 3 FGO) - comment, Internationales Steuerrecht, edition no. 3 from February 3, 2011

Prior Experience

  • January 2020 - present, Partner, DLA Piper UK LLP Frankfurt
  • September 2016 - December 2019, Partner, DLA Piper UK LLP Frankfurt, Co-Country Managing Partner Germany
  • August 2013 - August 2016, Partner, DLA Piper UK LLP Frankfurt, Location Head Tax Germany
  • August 2010 - July 2013, Managing Director at a law firm in Frankfurt am Main
  • January 2008 - July 2010, Local Partner at a global law firm in Frankfurt

Tax Advisor

Dr. Konrad Rohde has been a qualified tax advisor since 2007.

Memberships And Affiliations

  • Hessian Chamber of tax Advisor, Frankfurt
  • Registered Association of Lawyers, Tax Law

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