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+49 221 2091 542


Transfer Pricing and Tax Litigation

Oppenhoff & Partner Rechtsanwälte
Member of the tax committee of the American Chamber of Commerce in Germany (AmCham) since 2009
Cologne, Germany

Academic Background

  • Educated as a tax inspector within the North-Rhine-Westphalian tax administration from 1975 to 1978 including university of applied sciences in Nordkirchen (Diplom-Finanzwirt)

  • University of Bochum – legal state exams

  • University of Bochum –doctorate in tax law

  • University of Bochum -5 years assistant to Prof. Kruse (professor focusing on tax procedural law)

  • Tax-Associate with Boden Oppenhoff & Schneider as of 1987

  • Tax-Partner with Oppenhoff & Rädler and Linklaters and predecessor firms as of 1991

  • Founding partner of Oppenhoff & Partner mbB from 2008 till today


  • Numerous articles and essays on transfer pricing and procedures (MAP/APA/arbitration) including i.a. the German chapters in:

    • Thomson Reuters European Lawyer, Transfer Pricing and Tax Avoidance

    • Thomson Reuters European Lawyer, Tax Litigation

Notable Engagements

  • German manufacturer with European distribution subsidiaries, transfer pricing dispute involving 15 countries from MAP to arbitration and subsequent APA´s

  • Litigation on company valuation

  • Various pharmaceutical multinationals on disputes about German profitability of distribution entities including litigation

  • Dispute on arms-length royalty for Swiss multinational

  • Advise in tax audits on relocation of functions for i.a. manufacturing, distribution, R&D, services

  • Dispute on cash-pool remuneration

  • MAP-procedure for permanent establishments

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