Steckel Legal & Tax AG

Criminal tax proceedings lead unexpectedly to extreme situations in respect of tax-, economic- and personal issues. The client is completely at the mercy of tax- and investigating authorities.

Defending a client in criminal tax proceedings requires a highly competent consultant: Starting by securing the entrepreneurial existence by negotiating with banks, financial authorities, prosecution and courts right up to successfully finalising the proceedings.

In order to be successful in criminal tax proceedings, one has to be an expert in tax law. And it is exactly here where our law office comes in with our know-how and specialised knowledge. Due to this specialisation and experience we approach solutions that go way beyond the ‘classic‘ criminal defence.

We offer advice on:

Tax investigation matters
Adversary taxation procedures
Self-denunciation mandates
Main hearings at criminal courts
Information- and administrative assistance proceedings of foreign countries
Criminal proceedings against professionals (solicitors, auditors, tax consultants)

Self-denunciation

The path to tax honesty with impunity

The most important reason for a self-denunciation is to be protected against being punished for having evaded taxes.

A self-denunciation submitted to the relevant tax authority remains unpunished. For two decades we have advised and accompanied clients successfully regarding questions concerning a self-denunciation. We prepare all documents, establish value-added taxes, prepare the necessary explanations, negotiate with authorities and show ways to optimise a self-denunciation. As we are located in Zug we can guarantee that in respect of preparatory work and consultations, no bank documents will find their way across the border, thus avoiding unnecessary risks of disclosure.

Tax disputes in Germany

Negotiating successfully with tax authorities

Apart from a specific know-how and negotiating skills, successful results also require us to be ready for disputes - if necessary - in front of a court. We represent our clients in all phases of a tax dispute and results-driven outcomes for our clients are our top priority.

Opposition proceedings at authorities

An unlawful tax assessment can be challenged with an appeal. The tax authority will decide on the appeal. If the tax office does not allow the appeal, action can be raised at tax courts. An effective legal protection requires in-depth knowledge of the material tax law and procedural law.

Proceedings on a temporary legal protection

Challenging a tax assessment does not change the due date of the fixed taxes. Upon application it is possible to suspend the enforcement of the challenged tax assessment, if the legality is in serious doubt or in case enforcement would lead to unnecessary hardship. The enforcement can be suspended either by the tax office or the fiscal court.

Proceedings of enforcement, deferment and remission

Even completely ascertained assessed taxes do not always have to be fully paid by the taxpayer. The enforcement-, deferment- and remission procedures of the tax law allow the taxpayer to influence amount and modalities of payments in his favour.

Disputed company audit procedures

As a rule company audits usually establish value-added taxes. By intervening at an early date the results can be influenced while the audit is ongoing. If it is not possible to achieve a mutual conclusion, objections can be raised with regard to the report. Objections can also be raised during opposition proceedings, following tax assessments based on company audit results.

Legal actions at fiscal courts

Provided the tax office does not accept the objection against a challenged tax assessment, the next step would be to file a legal action at the fiscal courts. Should the tax office not decide upon an objection in due course, an action for failure to act can be raised that removes the necessity to conclude the previous opposition proceedings. The senate with three judges and two non-professional judges or a single judge decides on legal actions. Material tax law and procedural law work together in this.

International corporate and asset succession

Accompany family assets over generations

We advise and implement international asset- and corporate successions.

Maintaining and securing family assets need to be planned forward-looking and long-term. Apart from optimally arranging taxes such that inheritance tax and gift tax can be reduced or avoided altogether, also geography and choice of law play an important role in an increasingly global world.

As the structure of assets and life style are often geared internationally, succession planning has become a cross-border challenge.

As an internationally oriented law office we work out tailor-made solutions together with you:

Developing a comprehensive concept of succession for private persons as well as for entrepreneurs
Designing all necessary inheritance- and/or gift tax-related agreements
Setting up matrimonial regime regulations
Optimising taxes of the asset- and corporate succession
Looking after and implementing foundation concepts
Accompanying the moving to/moving away with regard to legal and tax issues within the scope of the asset succession
Execution of wills
Advising on questions regarding international inheritance- and matrimonial regimes (IPR and EU-ErbVO)
Representation out-of-court and in court

Family Office Consultation

Legal- and tax advice in an increasingly more complex global world

We advise families, single- as well as multi-family offices regarding the relevant legal and tax-related issues and questions in an increasingly more complex international world, balancing the protection of assets and family and compliance. Historically viewed the term Family Office is a neologism of the past few decades.

So far it has always been such that from a specified level of assets and connections abroad, specialist competence and personnel is needed to manage and organise the assets and family members. Within the past ten years the focus in the family office consultation and above all in the international environment has changed a lot. Increasingly complex compliance regulations, CRS, exchange of information regarding tax issues as well as the downside of digitalisation that is the legitimate securing of privacy and client protection versus the electronic availability / transparency of all relevant data have created a new challenge.
The danger for all those concerned, be it family members or the family office to get into a dispute with the financial authorities has increased remarkably. Due to the complexity relevant adaptations and partly mandatory changes are rather expensive and need relevant know-how, planning and experience.

We advise all those concerned in identifying and reducing possible risks.
We advise all those concerned and external service providers in developing future-oriented structures focussing on securing assets and tax compliance.
We represent family members or family offices in disputes with the tax authorities.

Law Office

Our core competences

Specialised, experienced, international

More information

Curriculum Vitae

Christopher E. Steckel

More information

Our core competences

Specialised, experienced, international

We advise all those concerned in identifying and reducing possible risks.
We advise all those concerned and external service providers in developing future-oriented structures focussing on securing assets and tax compliance.
We represent family members or family offices in disputes with the tax authorities.

Curriculum Vitae

Christopher E. Steckel

Professional education
Christopher E. Steckel was born in Munich and spent his childhood and later on his working life in various different countries. Following his high school graduation (A-levels), he studied law in Munich at the Ludwig-Maximilian-University between 1986 and 1990. While he was studying he had been a research assistant at the Chair for Commercial and Business Law of Professor Hopt. During his time as trainee lawyer he acquired his first international experiences in the renowned French law office Foucaud & Associés in Paris. Already while he was working as a trainee lawyer he started to work for the KPMG Deutsche Treuhandhand, Wirtschaftsprüfungs- und Steuerberatungsgesellschaft AG in Munich in the section of tax consulting.

Career
In 1993 Christopher E. Steckel was admitted to the bar in Munich. In the same year he started to work for KPMG in the Tax & Legal department in Munich. Within the scope of his posting to New York between 2000 and 2002, he was part of building up the German Tax Center of Excellence for the German KPMG. In 2002 KPMG sent him to Zurich, where he subsequently set up and managed the German Tax & Legal Center in Switzerland. He has been living in Switzerland ever since. In 2004 Christopher E. Steckel was promoted to become an Equity Partner of the KPMG. He managed the KPMG German Tax & Legal Center in Switzerland right up to the end of 2012.

Apart from this operative consulting activity involving national and international clients, Christopher E. Steckel held a number of specialised- and manager functions across all those years at the KPMG:

2001 to 2007: Chief Operating Officer (COO) in the area of M&A Tax KPMG for Europe, Middle East, India and Africa (EMA)
2007 to 2012: COO for the overall area of Tax of the EMA Region and member of the EMA tax executive board
2010 to 2012: COO for Tax of KPMG Europe LLP and member of the KPMG Europe LLP tax executive board
2007 to 2012: Head of the department for international private clients & family offices of the EMA region and KPMG Europe LLP.

Between 2005 and 2006 he underwent the executive programme at the ESMT European School of Management and Technology in Berlin; and between 2008 and 2009 he participated in the KPMG MBA programme “Chairmen 25“ at INSEAD, the elite school for managers in France.
Christopher E. Steckel has always advised German and international private persons as well as companies in the area of tax law.

Law office

At the end of 2012 Christopher E. Steckel left KPMG at his own request and on best terms in order to set up his own law office. To this purpose he went into partnership with the existing law office Leisner to become Leisner Steckel Engler beginning of 2013.

Christopher E. Steckel left the partnership Leisner Steckel Engler on 31/12/2017 in order to open the law office STECKEL LEGAL & TAX AG in Zug. There still exists cooperation with the partnership Leisner Steckel Engler in Munich and Zurich on a close but economically separated basis.

Apart from being a member of the Munich and Upper Bavaria Bar Association, Christopher E. Steckel has also been a member of the Zurich Bar Association since 2013.

One of the main key issues within his activities since 2002 has been to give comprehensive advice in connection with self-denunciation. Beyond that, his activities comprise preventative consultations, representation in criminal preliminary proceedings, accompanying tax investigation audits right up to representation within the scope of main hearings at criminal courts.

The consultation comprises the overall range of investigations under criminal tax law in case of adversary issues towards the financial authorities, within the scope of company audits, in opposition proceedings and at all fiscal courts right up to the Federal Fiscal Court. A representation is extended to private persons as well as companies and entrepreneurs of any size and industry. During his professional activities, he has represented a number of well-known and highly exposed persons. His comprehensive experience in handling media subjects as well as protecting the privacy played an important role in these proceedings.

Giving advice on tax compliance projects to prevent tax damage is also part of the consultation. Here Christopher E. Steckel supports national and international entrepreneurs and companies to condition relevant criminal issues of internal as well as external investigations and also preventatively to avoid criminal tax allegations. One focus is placed on checking and adapting accounting- and entrepreneurial processes to be in compliance with tax-law provisions. The objective is to adapt processes and procedures in order to ensure that the regulations regarding the tax law are observed.

Since 1993 another main focus has been the consultation in the area of international tax law and international tax planning. The range of advice comprises the adaptation of tax-related structures to new standards right up to preventing tax risks of internationally acting companies, families and private persons. In connection with the globally progressing automatic exchange of information and data, he advises families and family offices in this process of transformation and also on preventative measures to avoid tax risks.

Christopher E. Steckel gives regular talks at various different seminars on tax in Switzerland, as well as at the Chair Banking and Finance of the Uni Zurich on the subject of Tax & Compliance. In his function as solicitor Christopher E. Steckel works nationwide, as well as in Europe and the U.S.

Christopher E. Steckel has lived and worked in Switzerland exclusively since 2002. However, due to his international clientele, his activities extend to countries all over the world.
His fluent working languages are English, French and Italian.

Contact

Always there for you

Grienbachstr. 11
CH- 6300 Zug

Tel +41 44 260 4000
Fax +41 44 260 4004

Email christopher@remove-this.steckel.legal

Christopher E. Steckel

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