Dr. Andreas Knebel
Andreas' practice is focused on German and international taxation issues.
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. Furthermore, Andreas is a member of the Management Board of the association Steuerrechtswissenschaftliche Vereinigung Heidelberg e.V. (strwv-heidelberg.de)
Advising a group of minority shareholders in Inexio KGaA, a fast growing provider of fibre-based internet access services in Germany, in connection with the sale of their shares to an affiliate of Warburg Pincus. We also advised the supervisory board of Inexio Informationstechnologie und Telekommunikation KGaA in connection with a complex amendment to the investment and shareholders agreement governing the acquisition.
DZ BANK/WGZ BANK merger, 2016
Advising DZ BANK on its merger with WGZ BANK. The merged entity has started off as "DZ BANK. Die Initiativbank" on August 1, 2016 and serves as consolidated central bank for more than 1,000 cooperative banks in Germany. In terms of the balance sheet, the merger resulted in the second largest credit institution in Germany based on a balance sheet total of around €509 billion in 2016.
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, 2017
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.
Regular Speaker at WCLF Conference in Frankfurt on "International Developments in the Taxation of IP Rights"
Case Studies: IP-Allocation in M&A Transactions and Reorganization, WCLF Tax und IP Gesprächsband 2016, Page 127 et seq. published by Springer Gabler (Praxisfälle: IP-Zuordnung bei M&A Transaktionen und Umwandlung) (author)
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)
Best Lawyer Germany in Tax Law, Handelsblatt 2021
Highly Recommended Lawyer: Tax, Germany, JUVE 2017/2018
Highly Recommended Lawyer: Germany, The Legal 500 EMEA 2013