Dr. Andreas Knebel | White & Case LLP International Law Firm, Global Law Practice
Andreas Knebel
Andreas Knebel

Dr. Andreas Knebel

Partner, Frankfurt

T +49 69 29994 1330

E aknebel@whitecase.com

Andreas Knebel is recognized as a Highly Recommended Tax Lawyer by JUVE 2014/2015.

Overview

Andreas' practice is focused on German and international taxation issues. A noted lawyer and advisor in this field, he also heads up the Firm's tax practice in Germany.

Andreas' significant experience and understanding of this area enables him to provide clients with strategic advice regarding complex tax matters, mergers & acquisitions, corporate restructuring and succession planning.

Drawing on his deep local knowledge, as well as his many dealings in the international regulatory environment, Andreas guides clients through technically complicated tax laws, in relation to a range of domestic and cross-border issues.

Results-focused and value-driven, Andreas also has a track record of supporting companies who are faced with potentially costly tax audits and disputes with tax authorities, both out of court and before German fiscal courts. Committed to helping clients to minimize their tax liabilities, he also helps to deal with technically complicated transfer pricing issues and customs duties.

To provide his clients with truly cutting-edge advice, Andreas stays abreast of the latest developments in taxation policy. His opinions on these matters are often featured in leading German legal publications.

Bars and Courts

  • Tax Lawyer
  • Tax Advisor
  • Rechtsanwalt

Education

  • Dr jur, Ruprecht-Karls-University of Heidelberg
  • Second State Exam, Higher Regional Court of Karlsruhe
  • First State Exam, Ruprecht-Karls-University of Heidelberg

Languages

  • German
  • English

Experience

PATRIZIA Alternative Investments GmbH (PAI), 2016

Representation of PATRIZIA Alternative Investments GmbH (PAI) in connection with two portfolio transactions acquiring retail assets for a special regulated funds. The total deal volume comprises approximately EUR 500 million at total. Our advice combined all aspects of the transactions, including real estate, M&A, corporate, tax structure and regulatory aspects, antitrust and bank finance.

Mitsubishi Electric Europe B.V., 2014

Advised Mitsubishi Electric Europe B.V. on tax and customs law issues at a national, European and global level, regarding the evaluation of a module manufactured and imported to Germany by our client.

Non-EU pension funds, ongoing

Advising non-EU pension funds (including, among others, Pension Fund Association, bcIMC) on the withholding of tax on dividend income, based on the case law of the European Court of Justice (ECJ).

Allianz Renewable Energy Fund (AREF), 2014

Advised Allianz Renewable Energy Fund (AREF) on tax issues in connection with the purchase of the Great Glemham solar park, located 150 km outside London. Based on its capacity of 19.5 Megawatts, the solar park supplies nearly 5,000 UK households with environmentally-friendly electricity.

DZ Bank AG, 2014

Advised DZ Bank AG on tax issues related to the Foreign Account Tax Compliance Act (FATCA) and on lawsuits for damages filed by investors.

Sanrio GmbH, ongoing

Advising Sanrio GmbH in connection with a mutual agreement procedure (APA - Advance Pricing Agreement) between Germany and Japan. Andreas’ advice related to the structuring of license fees (including, among others, the trademark "Hello Kitty").

Talmor group, ongoing

Advising the Talmor group’s real estate portfolio on tax law matters related to its restructuring of existing financings of approximately €2 billion. Andreas also advised on international tax planning related to Talmor’s affiliates in the Netherlands, Israel, Luxemburg and Switzerland and joint venture partners.

Samsung Electronics GmbH, 2012

Advised Samsung Electronics GmbH on the acquisition (as an asset deal) of Sonoace Deutschland GmbH, an ultrasound equipment manufacturer. This challenging mandate also involved providing advice on the regulatory requirements for medical devices, and the requirements associated with the sale of ultrasound equipment. The successful completion of this acquisition within a short period of time also represented a significant achievement.

Speaking Engagements

"International Developments in the Taxation of IP Rights", 2 April 2014: WCLF Conference, Frankfurt, (panelist)

"Impact of the Authorized OECD Approach on Profit Allocation between Head Office and Permanent Establishment", 22 March 2012: as part of the WCLF Conference, Frankfurt , (with Thomas Schmidt)

Publications

  • Double taxation and BEPS, IStR, Issue 22, pp. 832-840, 2014, (Doppelbesteuerung und BEPS) (co-author with Roland Hummel)
  • Tax Treatment of Collaterals in Company Groups, IStR, Issue 2, p. 42 et. seqq., 2012, (Sicherheitengestellung im Konzern) (co-author with Klaus Sabel and Thomas Schmidt)
  • Submittal to the European Court of Justice: Effect of Free Movement of Capital on Inheritance Tax – Commentary to BFH Resolution from 15.12.2010 – II R 63/09, NWB-EV, Issue 4, pp. 124-127, 2011, (Vorlage an den EuGH: Auswirkung der Kapitalverkehrsfreiheit auf die Erbschaftsteuer) (co-author with Cornelia Geißler)
  • Comments on European Court of Justice, Judgment 22 April 2010 – Rs. C-510/08, Vera Mattner, NWB-EV, Issue 8, pp. 263-267, 2010, (Geringer Freibetrag bei beschränkter Steuerpflicht gemeinschaftswidrig. Anmerkungen zum Urteil des EuGH v. 22.4. 2010 – Rs. C-510/08, Vera Mattner) (co-author with Christina Hüschemenger)
  • Tax Advantage Deductions on Punitive Claims from Investments in Media and Shipping Funds, BB, Issue 22, pp.1316-1320, 2010, (Anrechnung von Steuervorteilen auf Schadensersatzansprüche aus Beteiligungen an Medien-und Schiffsfonds) (co-author with Thomas Schmidt)

Awards & Recognition

Highly Recommended Lawyer: Tax, Germany, JUVE 2014/2015

Highly Recommended Lawyer: Germany, The Legal 500 EMEA 2013