20+ years of experience in M&A (buy- and sell-side tax due diligence, tax structuring and SPA tax advice)
10+ years of experience in German PE tax compliance for international PE funds
Munich
@alvarezmarsal
LinkedIn
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Thomas Funk is a Senior Director with Alvarez & Marsal Tax GmbH in Munich. He brings more than 20 years of experience in M&A tax and private equity tax compliance.
Mr. Funk’s notable assignments include tax due diligence (buy-and sell-side), tax structuring in international M&A transactions, and German tax compliance for larger PE funds.
Most recently, Mr. Funk was responsible for the German tax compliance of numerous international private equity funds. He is expert in separate and uniform declaration of PE funds’ income for German investors, CFC/PFIC tax compliance, and declaration of return of capital (Einlagenrückgewähr). Mr. Funk has worked with clients across various industries, mainly private equity funds.
Prior to joining A&M, Mr. Funk spent more than 12 years in the M&A Tax /PE Tax Compliance Department at Deloitte in Munich and Frankfurt.
Mr. Funk earned a master’s degree in taxation from the University of Florida and is an attorney at law and a Certified Tax Advisor. He is a member of the Chamber of Certified Tax Advisors (Steuerberaterkammer) and the Lawyer’s Chamber (Rechtsanwaltskammer). Mr. Funk regularly publishes articles in German tax journals about current tax aspects of M&A tax /PE tax compliance.
Im German Tax Update dieser Woche besprechen wir Folgendes: Veräußerungsgewinn bei mehrstöckigen Personengesellschaften: BFH schafft erstmals Klarheit bei der gewerbesteuerlichen Behandlung, und EuGH bestätigt: Vorsteuerabzugsverweigerung und gesamtschuldnerische Haftung bei Umsatzsteuerbetrug sind miteinander vereinbar.
In this week’s German Tax update, we discuss the following: Disposal Gains in Tiered Partnerships: BFH Provides First Clear Guidance on Trade Tax Treatment, and CJEU Confirms: Denial of VAT Deduction and Joint and Several Liability in Cases of VAT Fraud Are Compatible.
A change in the German tax law obliges (Private Equity) Funds that are resident outside of Germany to file German partnership tax returns in case they have more than one German investor.
Private equity (PE) funds with at least two German tax resident investors are required to file an annual partnership tax return in Germany, even if they do not have taxable presence in the Germany.
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On 9 October 2022, the UAE Ministry of Finance (MoF) published Federal Decree Law No. 47 of 2022 (UAE Corporate Tax Law). The UAE Corporate Tax Law applies to Taxable Persons operating in the UAE and is effective for financial years beginning on or after 1 June 2023.
