Caroline advises private equity and venture capital funds as well as their investors on all issues of national and international tax law. Her main areas of expertise are the taxation of cross-border corporate structures and permanent establishments. This includes tax advice on and the structuring of complex international business models, the optimization of tax structures as well as the analysis and minimization of tax risks in a cross-border context. In addition, Caroline provides comprehensive support to companies and high net-worth individuals in tax disputes with the tax authorities.
Education and Career
Caroline studied German and French law in Potsdam and Paris. Parallel to her doctoral studies, she worked as a research assistant to Prof. Dr. Jens Petersen as well as in the Tax Practice Group of SMP.
Caroline completed her legal clerkship at the Hamburg Higher Regional Court including stints with the Hamburg tax authorities, at the Hamburg Fiscal Court, and the Tax Practice Group of Freshfields Bruckhaus Deringer.
Caroline is a member of the International Fiscal Association (IFA), the Young IFA Network and the Women in IFA Network (WIN).
Qualifications
- German qualified attorney (Rechtsanwältin)
- Ph.D. in law (Dr. iur.) (University of Potsdam)
- LL.B. (University of Potsdam)
- Licence en droit (Université Paris-Nanterre)
Languages
- German
- English
- French
- Korean
- Commentary on Secs. 43b, 50g and 50h German Income Tax Act (EStG),
in: Oppel/Martini/Oertel, Internationales Steuerrecht, Dr. Otto Schmidt KG (forthcoming) [in German] - Place of Management and Tax Evasion by Omission,
FR 2025, p. 120 (together with Dr. Thomas Töben) [in German] - Place of Management and Tax Evasion by Omission: Supersession of the Legal Institution of De Facto Management by the Person with Powers of Disposal within the Meaning of Sec. 35 German Fiscal Code (AO),
in: Steuerkritik, Commemorative Volume for Andreas Musil (ed. Markus Heintzen, Andreas Richter, Thomas Stapperfend, Christian Waldhoff), Dr. Otto Schmidt KG 2024, p. 387 (together with Dr. Thomas Töben) [in German] - From Center via Forming of the Will to Permanent Establishment,
FR 2024, p. 658 (together with Dr. Thomas Töben) [in German] - Requirements for the Establishment of a Management Permanent Establishment. Comment on the New Decree on the Application of the German Fiscal Code (AEAO) of 5.2.2024 on Secs. 10, 12 German Fiscal Code (AO),
DStR 2024, p. 592 (together with Dr. Thomas Töben) [in German] - On the Establishment of a Domestic Management Permanent Establishment. Comments on Berlin-Brandeburg Fiscal Court of 28 June 2023 - case no. 11 K 11108/17,
DStR 2023, p. 2708 (together with Dr. Thomas Töben) [in German] - My Heart Beats Tax – The 1st Summer Time Tax in Hamburg,
IStR 20/2023, II-VI [in German] - Management Permanent Establishment – Misconceptions and Clarifications,
DStR 2023, p. 305 (together with Dr. Thomas Töben) [in German] - Management Permanent Establishment: What is known – What should be known,
Handelsblatt Steuerboard, 26 January 2023 (together with Dr. Thomas Töben) [in German] - Addition of previous acquisitions in the new inheritance tax law,
DB 2022, p. 1736 (together with Jürgen E. Milatz) [in German] - Tax Loss Utilization in the Tax Retroactivity Period. Paragraph 2(4) German Reorganisation Tax Act: Legitimate Anti-Tax Abuse Measure or Unconstitutional Obstacle to Restructuring?,
Nomos 2021 [in German] - Taxation of Carried Interest (Part 2),
DStR 2019, p. 573 (together with Dr. Thomas Töben) [in German] - Taxation of Carried Interest (Part 1),
DStR 2019, p. 526 (together with Dr. Thomas Töben) [in German]
Direct message to Dr. Caroline Schrepp