Thomas Gericke focuses on multinational enterprises in structuring their cross-border activities, assisting with the implementation of respective structures, particular in post-merger integration settings.

He further supports clients to negotiate Advance Pricing Agreements for these structures and to defend them in tax audits.

Thomas advises clients on audit and changing their price setting from “reactive to proactive” under consideration of the arm’s length principle.

From a transfer pricing perspective, he also advises and assists clients in case where tax return corrections are required under the German Fiscal Code (Sec. 153) and advises clients with regard to self-disclosure in case of tax evasion.

He further gives advice on tax audit adjustments via mutual agreement/arbitration procedures under both, tax treaties and the European Arbitration Conventions respectively.