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Rainer-Jürgen Hartmann LLM

Senior Associate
About

Rainer Hartmann practices in the area of Transfer Pricing (TP), a specialised field within Tax.

His work encompasses i.a. the following fields of work: TP Structuring, TP Compliance, Permanent Establishments (PEs), national and international tax audits, appeal and tax litigation procedures, APA, MAP and valuations for TP purposes. His clients include companies in a range of sectors including automotive, chemicals, banking, industrial and media.

Professional QualificationsSteuerberater registered with Steuerberaterkammer Hessen

EXPERIENCE

  • Preparing the TP model for one of the worldwide biggest electric car manufacturer for its expansion in Germany.
  • Successful TP tax audit settlement for one of the biggest US motorcycle manufacturer with respect to its product transactions between UK and Germany saving millions of EUR of additional CIT in Germany.
  • Successful TP tax audit settlement for a big German/Chinese owned automotive supplier with respect to licence transactions between Germany and China saving millions of EUR of additional CIT in Germany.
  • Successful TP tax audit settlement for a big US owned battery manufacturer with respect to financing transaction between the US and Germany saving millions of EUR of additional CIT in Germany.
Languages
  • German
  • Inglés
Education
  • Vienna University of Economics and Business, LLM, 2016
  • Vienna University of Economics and Business, BSc Economics, 2014
  • Vienna University of Economics and Business, LLB, 2012

Awards

  • Best Bachelor Thesis in Tax Law Award, 2013 - “The place of taxation within chain transactions”
  • Publications

    • The digital Permanent Establishment – Recent developments, IWB 04/2018, NWB publisher
    • Ende der Diskussion über den in Deutschland Steuersystem-fremden Price-Setting-Approach, in: Die Unternehmensbesteuerung 2021, p. 17-20 (with Dr. Ulf Andresen)

    Seminars

    • Seminar in Munich on 11 March 2020 - “Transfer Pricing Post-BEPS in Germany”

    Prior Experience

    • 2017-2019; Senior Consultant for Tax/Transfer Pricing at PwC in Frankfurt/Germany
    • 2014-2015; Junior Consultant for Tax/M&A at PwC in Vienna/Austria

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