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Associated Partner*

Dr. Antonia Scheinbacher

Munich

Antonia advises multinational corporations, medium-sized companies, and growth companies on issues relating to international tax law and transfer pricing.
Her main areas of expertise include the tax structuring of international corporate activities, advising on permanent establishments and transfer pricing systems, clarifying related issues of employee taxation, and setting up tax compliance management systems in the field of international tax law. She supports her clients in ongoing and project-related issues as well as in the context of tax audits.

Education and Career

Antonia studied business administration with a focus on tax law at the Catholic University of Eichstätt-Ingolstadt. In addition to her professional work at Flick Gocke Schaumburg in Munich, she completed her doctorate in international tax law at Friedrich-Alexander-University Erlangen-Nuremberg.
Before joining YPOG, Antonia worked for several years as an in-house tax advisor and senior manager in the field of international tax law and transfer pricing at two Munich-based multinational corporations. Prior to that, she worked as a tax assistant and tax advisor focusing on international tax law and transfer pricing at Flick Gocke Schaumburg and Peters, Schönberger & Partner in Munich.
Antonia is a member of the International Fiscal Association (IFA) and the Women of IFA Network (WIN).

Experience

  • Transfer pricing modeling/structuring: Design of transfer pricing strategy, planning, implementation, and optimization of transfer pricing models/structures, including transfer pricing determination and analysis of restructuring from a transfer pricing perspective
  • Operational transfer pricing: Support in the implementation and monitoring of transfer pricing processes, including the preparation of transfer pricing guidelines and directives
  • Transfer pricing documentation: Preparation of Master Files, Local Files, CbCR
  • Transfer pricing litigation: Support with tax audits, application for mutual agreement procedures and advance pricing agreements
  • Review and design of recommendations for action in cross-border business activities (inbound/outbound) from a transfer pricing perspective and procedural support for their implementation
  • Identification and comprehensive ongoing tax support for domestic/foreign permanent establishments, including the legally required documentation
  • Support in the design and (procedural) implementation of new work/remote work models, global matrix structures, and general questions regarding cross-border employee taxation
  • Design, implementation and optimization of tax compliance management systems in the field of international tax law

* not a shareholder of YPOG GmbH & Co. KG

Qualifications

  • German qualified tax advisor (Steuerberater)
  • Certified advisor for international tax law (Fachberater für Internationales Steuerrecht)
  • Dr. rer. pol. (Friedrich-Alexander-Universität Erlangen-Nürnberg)
  • Master of Science

Languages

  • German
  • English

  • Commentary on BFH, judgment of December 18, 2024 – I R 47/21
    DStR 2025, 1013 (together with Dr. Christoph Gradl) [in German]
  • The permanent establishment and the criterion of power of disposal: A never-ending story?
    IStR 2024, 557 (together with Dr. Christoph Gradl) [in German]
  • Selected questions of doubt regarding local jurisdiction in the case of conversions in real estate transfer tax law
    DStR 2016, 1503 (together with Manuel Brühl and Dr. Christian Joisten) [in German]
  • Analysis of tax law uncertainty in tax planning using game theory – illustrated by the case of relocation of functions (dissertation)
    Verlag Dr. Kovac, 2016 [in German]
  • The taxation of private real estate sales in Germany and Austria: a comparison,
    in: Krenzin/Friedrich/Brähler (eds.), National and international business tax planning: Festschrift on the retirement of Prof. Dr. Dr. Christiana Djanani, Bad Sooden-Allendorf 2014, pp. 143–160 [in German]
Dr. Antonia Scheinbacher

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