Maximilian Cleve LL.M. (Tilburg)
Associate
Baker McKenzie Rechtsanwaltsgesellschaft mbH von Rechtsanwälten und Steuerberatern
Biography
Max Cleve is an associate in the Firm's Tax Practice Group. He advises multinational enterprises on international tax law, especially on permanent establishments and transfer pricing.
He is admitted to the German bar as an Attorney (2022). Before re-joining the Firm in 2025, Max structured private equity funds at a major German law firm and resolved tax disputes at a renowned German tax boutique.
Practice Focus
Max advises multinational enterprises on international tax law, especially on permanent establishments and transfer pricing. While he advises in both inbound and outbound situations, many cases involve US tech companies and their subsidiaries or permanent establishments in EMEA.
Representative Legal Matters
- Represented several MNEs in the software, financial, healthcare and energy industry in tax audits at their German subsidiaries or permanent establishments. Frequent issues include alleged IP transfers, DEMPE functions and re-characterization of entities (e.g. from contract R&D / manufacturing to co-entrepreneurship).
- Represented a US automotive supplier in an APA and rollback procedure regarding royalty rates for intra-group licenses.
- Represented a French consumer goods company in a MAP regarding intra-group distribution services.
- Advised several MNEs on permanent establishment risks (both fixed place of business and agency PEs) related to datacenters.
- Advised a European aviation company on the profit allocation to its German construction PE.
- Advised several US tech and software companies on the transfer pricing treatment of stock-based compensation and other forms of equity-based remuneration.
- Advised a US chemicals company and a US medical technology company on interest deductibility and the (re-)structuring of intra-group loans.
Professional Associations and Memberships
- International Fiscal Association (IFA) - Member
Admissions
- Germany (2022)
Education
- Tilburg University (LL.M. in International Business Taxation) (2024)
- Higher Regional Court of Dusseldorf (Second State Exam in Law with Traineeships at the Federal Central Tax Office and a Fiscal Court) (2021)
- University of Bonn (First State Exam in Law with Focus on Corporate, Capital Markets and Tax) (2018)
Languages
- German
- English
Baker McKenzie Rechtsanwaltsgesellschaft mbH von Rechtsanwälten und Steuerberatern is registered with the Local Court of Frankfurt/Main (registered seat) HRB 123975. It is associated with Baker & McKenzie International, a Verein organized under the laws of Switzerland.