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Janina Tackmann

Senior Associate
About

Janina Tackmann is a German qualified tax advisor advising multinationals and medium-sized businesses in German and international tax matters as well as transfer pricing.

Janina focuses on the design and implementation as well as the defense of transfer pricing structures in controversy situations.

Her clients include companies in a range of sectors including Life Sciences, Consumer Goods, Food and Retail, Financial Services, Industrials, Technology, Infrastructure, Construction and Transport as well as Real Estate.

Janina is particularly experienced in the design of transfer pricing structures as well as appeal and mutual agreement proceedings.

She has gained significant experience in the area of transfer pricing and international tax and advises multinational clients additionally in different corporate tax matters such as global mobility and VAT.

Professional QualificationsSteuerberaterin registered with Steuerberaterkammer Hessen

EXPERIENCE

  • Successful tax audit defense / administrative appeal procedure for US multinational in relation to an alleged multi-million EUR transfer of business function out of Germany.
  • 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.
  • Design and implementation of tax and transfer pricing model for EU-wide distribution activities of a German-based wholesaler involving 10 jurisdictions.
  • Tax audit defense / administrative appeal procedure for a European pharmaceutical group in relation to an income adjustment assessed by the tax audit due to an alleged compensation claim from a billion-euro payment in connection with patent disputes.
  • Transfer pricing structuring and assessment of intercompany financing arrangements in relation to inbound and outbound private equity / debt investments in the (renewable) energy and real estate sectors and transfer pricing aspects of third-party bond financing.
  • Advising a DAX company on a global carve-out of one of its business units as well as the post-merger transfer pricing structuring and financial modelling in relation to more than 20 jurisdictions.
  • Design and implementation a new global transfer pricing system across various jurisdictions for an Italian and German-based wholesaler in the consumer goods industry.
  • Initiating and advising on a Danish-German Advance Pricing Agreement for a technology company.
  • Valuation of a Luxembourg-German transfer of intangibles for one of the largest European pharmaceutical and chemical companies.
Languages
  • English
  • German
Education
  • Goethe-University Frankfurt am Main, Master of Science Business Administration (Finance and Accounting), 2017
  • Georg-August-University Göttingen, Bachelor of Science Business Administration (Finance, Accounting and Taxation), 2014

Presentations and Seminars

  • English-language webinar series: DLA Piper – Transfer Pricing Insights Germany, 13 May 2024

Prior Experience

  • Associate Transfer Pricing in a “Big Four” firm in Frankfurt, 2017 to 2019

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