Dr. Stephan Schnorberger works for international businesses to facilitate cross-border activities in today's tax environment and to advocate the rule of law in transfer price controversies. Stephan also supports businesses by economic analysis and advocacy in competition matters such as business combinations, cartel damage cases and questions of abuse market power. Stephan is recurrently recognized as top advisor in international tax and transfer pricing on a global and national scale in industry rankings such as Euromoney Expert Guides, Wirtschaftswoche, Handelsblatt Research Institute, JUVE.
Stephan focuses his practice on transfer pricing, business restructuring, supply chain modeling, international tax planning, high value audit defenses, complex tax litigation, competition and regulatory economics.
Representative Legal Matters
- Advised on global transfer price review and planning by means of profit split.
- Advised on strategic business model review to optimize customs and transfer pricing.
- Represented clients on tax planning, transfer pricing and valuation for outbound transfer of intellectual property.
- Litigated against exit taxation of reallocation of production.
- Successful Federal Tax Court revision of lower court upholding of disclosure requests.
- Successful tax court claim against transfer price adjustments of intercompany loan interests.
- Successfully averted multilateral tax audit through tax court action.
- Advised on valuation of compensation payments on pan-European restructuring of manufacturing and sales.
- Advised on APAs and competent authority procedures within and beyond Europe.
- Advised on audit defenses of inbound principal models, partnership and branch structures.
- Recommended as Top Advisor 2020 for International Tax in key German financial magazine Wirtschaftswoche, survey in cooperation with Handelsblatt Research Institute Edition 32/2020
- Best of the Best, Euromoney Expert Guide 2020
- Best Lawyers in Germany 2019 for Tax, Handelsblatt survey in cooperation with Best Lawyers, 2019
- Recommended for Tax Controversy in Transfer Pricing, JUVE 2018
- Germany Transfer Pricing Firm of the Year 2012, International Tax Review, May 2012
- Germany Transfer Pricing Firm of the Year 2010, International Tax Review, May 2010
Professional Associations and Memberships
- International Fiscal Association (IFA) - Member
- Tax Bar Dusseldorf (Germany) - Member
- Schmalenbach-Gesellschaft für Betriebswirtschaft e.V. - Member
- German Tax Bar (1996)
- University of Nurmberg (Doctor of Business Administration) (1997)
- Certified Tax Advisor (Steuerberater) (1996)
- University of Nurmberg (M.B.A.) (1992)
- Wayne State University (Master of Arts Economics) (1989)
Co-Author, (with Rabea Lingier), "Germany - Chapter 7", The Transfer Pricing Law Review, Edition 4, August 2020
Co-Author, (with Nils Etzig) "Verrechnungspreise in der Praxis nach dem ATAD-UmsG - Anmerkungen zum Referentenentwurf vom 24.3.2020", Betriebs-Berater, BB 30.2020, July 2020
Co-author (with Rabea Lingier), "Transfer Pricing Germany," Update 2020, Baker McKenzie EMEA Transfer Pricing Handbook, July 2020
Co-author, "Covid 19: Impact on (the Other) TP," Baker McKenzie Bloomberg Tax Special Report, April 2020
Author,"Steuerrechtliche Aspekte grenzüberschreitender Vertragsgestaltung - Lektion 11", 3rd edition, FORUM Institut für Management GmbH, July 2020