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Stefan Richter

Stefan has more than 25 years of experience in international tax law, tax structuring advice and M&A transactions. His focus lies on advising DLT projects and token-based business models. In addition, Stefan advises on financing rounds of start-ups, company acquisitions and sales, and structuring issues in international contexts.

Education and Career

Stefan studied business management and engineering in Hamburg. He started his career at Deloitte in Berlin and subsequently worked - with a focus on medium-sized M&A transactions - as a partner in a Hamburg tax boutique. Before joining YPOG, he was again active as a tax partner for Deloitte.
Stefan is a lecturer at Bucerius Law School in Hamburg and frequently lectures at national and international tax conferences of the IBA and ABA. He is a founding member and board member of Hamburger Steuerdialog e.V.


Stefan's recent work highlights include advising:

  • Structuring and support of international DLT projects, token-based networks and business models including the structuring of employee participation schemes.
  • Tax due diligence on the buyer side, tax structuring and transaction support in various M&A transactions
  • Tax support and advice on financing rounds
  • Post-transaction support
  • Asset structuring and asset succession


  • German qualified tax advisor (Steuerberater)
  • Graduate in Engineering and Business Economics (Diplom-Wirtschaftsingenieur)


  • German
  • English


  • Withholding tax on token-based debt securities in Germany and Austria
    RdF 2022, 194 (together with Tatjana Polivanova-Rosenauer and Felix Schawaller)
  • Federal Ministry of Finance publishes application letter on the income tax treatment of virtual currencies and tokens
    ISR 2022, 205 (together with Dajo Sanning)
  • Taxation of Crypto Assets
    1st Edition 2021 (Editor together with Niklas Schmidt, Jack Bernstein and Lisa Zarlenga)
  • Taxation of Crypto Assets – Introduction (1.2.3 and 1.2.4); Country Guide Germany
    1st Edition 2021
  • Taxation of tokenized shares
    Beck.digitax 2021, 86 (together with Maximilian Offinger and Johannes Blöcher)
  • Bookkeeping obligation of a foreign real estate corporation (comments on Federal Fiscal Court decision)
    ISR 2019, 292-293 (together with David John) – [in German]
  • Tax-balance-sheet recognition of tokens as part of the business assets,
    FR 2019, pp. 407–412 (together with Katharina Schlücke) – [in German]
  • Does the preferential treatment of FDII, according to the US tax reform, trigger the limitation of Sec. 4j EStG? – The scope of Sec. 4j EStG and the possibility of a teleological reduction
    ISR 2018, 109 (together with Stefan Richter) – [in German]
  • What causes and requires the newly introduced license barrier according to § 4j of the German income tax act? 
    WPg 18.2017, 1090-1096 (together with David John) – [in German]
  • Bookkeeping obligation of a foreign corporation owning real estate (comments on Federal Fiscal Court decision)
    ISR 2016, 47-48 (together with David John) – [in German]
  • Taxation of US Law Firm LLP according to article 14 para 1 (comments on Federal Fiscal Court decision)
    ISR 2016, 198-200 (together with David Kater) – [in German]
  • Capital gains in course of withdrawals from a professional service partnership (essay)
    FR 2016, 606-615 (together with David John) – [in German]
  • Partnerships and international tax law
    2nd. Edn., 2015 (togehter with Franz Wassermeyer/Helder Schnittker) – [in German]
  • Professional service partnership and international tax law (compendium)
    in Wassermeyer/Richter/Schnittker (Eds.), Partnerships in international tax law, 2015 – [in German]
  • Co-entrepreneurs and permanent establishments (essay)
    FR 2015, 142-148 – [in German]
  • Planning is key (essay)
    private banking magazin, 04/2015, 30-32 (together with Michael Maßbaum) – [in German]
  • No cash accounting based loss determination in case of foreign bookkeeping obligations (comments on Federal Fiscal Court decision)
    ISR 2015, 162-163 (together with David John) – [in German]
  • Gift tax payer in case of a withdrawal from a partnership (comments on Federal Fiscal Court decision)
    FR 2015, 766-769 (together with David John) – [in German]
  • Foreign bookkeeping obligations and derivative local tax obligations (essay)
    ISR 2014, 37-42 (together with David John) – [in German]
  • Foreign bookkeeping obligations (comments on Federal Fiscal Court decision)
    ISR 2014, 158 (together with David John)
  • Application of gift tax in case of a withdrawal from a partnership (essay)
    Ubg 2014, 434-438 (together with David John) – [in German]
  • No cash accounting in case of foreign bookkeeping obligations (comments on Federal Fiscal Court decision)
    ISR 2014, 414-415 (together with David John) – [in German]
  • Cross-border partnerships – hybrid conversions (essay)
    GmbHR 2012, 1117-1128 – [in German]
  • International partnerships and crucial tax treaty questions (essay)
    FR 2010, 544-555 – [in German]
Stefan Richter

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