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Dr. Christian Port

Partner
Baker McKenzie Rechtsanwaltsgesellschaft mbH von Rechtsanwälten und Steuerberatern

Biography

Christian Port is a member of Baker McKenzie's International Tax Group based in Frankfurt. He is highly experienced in providing tax advice to German and foreign multinational companies in complex national and international corporate tax matters, with a strong focus on deal-related tax structuring and group reorganizations.

Christian joined Baker McKenzie’s Frankfurt office in 2009 and was elected partner in 2015. He studied law in Trier and London, was admitted to the German bar in 2009 and qualified as certified German tax advisor in 2011. Additionally, he also served as a research assistant at the Institute for Technical and Environmental Law at the University of Trier where he received his Ph.D. in law in 2011.

Christian has published numerous tax articles during his professional career and is a frequent speaker at national and international tax conferences.

Practice Focus

Christian's practice is devoted to international tax planning and global restructuring projects. His experience particularly lies in navigating the complexities of taxation within the dynamic landscapes of software, e-commerce, digital economy, and other high-tech industries. He also advises domestic and international clients on the tax-efficient structuring of inbound and outbound investments, (cross-border) corporate restructurings and other types of reorganizations, including acquisition and carve-out structuring, post-deal integration, joint venture structuring, IP migration and debt restructuring. In addition, he represents his clients in tax controversies, including tax audits and tax litigation as well as investigations and administrative procedures.

Representative Legal Matters

  • Tax advice to various multinational groups in relation to the extraterritorial taxation by Germany of IP transactions between non-resident taxpayers ("Sec 49") and representation before the German tax authorities, including the preparation of protective filings.
  • Tax advice to German headquartered multinational in relation to reorganization of Mexican group.
  • Tax advice to German headquartered multinational in relation to pre-IPO reorganization of German group.
  • Tax advice to German Dax40 multinational group in relation to a global post-acquisition integration in multiple jurisdictions.
  • Tax advice to German Dax40 multinational group in relation to the repatriation of cash by a Chinese subsidiary.
  • Tax advice to the majority shareholder of a German travel company in connection with the pre-IP restructuring into a Dutch dual resident company, including IPO-related tax advice and review of IPO prospectus.
  • Tax advice to a US multinational company in the SaaS industry and representation before the German tax authorities in relation to the refund of German withholding tax on SaaS user fees.
  • Tax advice to multinational pharmaceutical company on the tax efficient structuring of a Dutch IP holding company.
  • Tax advice to various software, e-commerce and digital economy companies on permanent establishment and withholding tax matters.
  • Tax advice in relation to M&A transactions, related pre- and post-deal structuring and internal reorganizations for various multinational groups.
  • Tax advice to a Swiss group in connection with the investigation of the Criminal and Administrative Offenses Department into certain exit tax and transfer pricing issues.

Professional Honors

  • Listed as Best Lawyer for Tax 2023 – Best Lawyers / Handelsblatt Ranking 2023

Professional Associations and Memberships

  • International Fiscal Association (IFA) – Member

Admissions

  • Germany (2009)

Education

  • Certified Tax Advisor (Steuerberater) (2012)
  • University of Bonn (Ph.D.) (2011)
  • State of Rhineland-Palatinate (Second State Examination) (2009)
  • University of Trier (First State Exam) (2004)

Languages

  • English
  • German

Publications

Publications

Co-author (with Sonja Klein, Lars Haverkamp, Udo Henkel, Thomas Schänzle), contributed article in handbook "Steuerrecht international tätiger Unternehmen," Verlag Dr. Otto Schmidt, 5th edition, 3 April 2018

Co-author, "Local Tax Court of Cologne Prevents German Federal Central Tax Office from Conducting Information Exchange with E6 Countries in Relation to Digital Economy," October 2015

Co-author, "EMEA Tax Newsletter," October 2015

Co-author, "German Parliament Passes Tax Amendment Act 2015," October 2015

Co-author, "Proposed Cancellation of German Participation Exemption in Relation to Capital Gains Derived from Shareholdings Below 10%," August 2015

Geschäftsführer: Dr. Alexander Wolff, Dr. Oliver Socher, Dr. Christian Vocke
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.