Lars Kelterborn

Essays and articles

• Hoke’s article, “Germany: Prosecutors Probing Transfers by Volkswagen’s Former CEO,” Tax Notes International, Aug. 6, 2018, pp. 624-625
• On the effectiveness of voluntary self-disclosures in the event of "minor incompleteness", DStR 2012, 640
• The comprehensive three-stage insolvency law reform and its tax effects, BB 2012, 1579 

Discussion of rulings

• Comment on the ruling by BFH of 23/08/2011, IX R 8/11, "Subsequent Consideration of Special Income-Related Costs in an Assessment", AO-StB 2011, 327
• Comment on the ruling by BFH of 14/03/2013, IX R 37/11, "Third-Party Expenses (Spouses) as subsequent costs of acquisition as per Art. 17 Income Tax Act?", GmbH-StB 2012, 233, EStB 2012, 200

The focuses of his work exclusively lie in contentious tax proceedings and advice regarding self-disclosure, e.g.:

• Defence in criminal proceedings for tax offences,
• Criminal tax law and commercial criminal law counselling, e.g. regarding self-disclosure,
• Support during contentious audits
• Execution of appeals and lawsuits against the financial authorities both in court and out of court
• International Tax Law

• Undeclared income from foreign capital assets (e.g. from Switzerland, Liechtenstein, Austria); use of foreign foundations
• Estate / inheritance containing undeclared funds - Legalisation of foreign capital assets / transfer of undeclared assets
• Entrepreneurial investment of undeclared funds abroad: Tax fraud, embezzlement, fraud, corruption
• Defence against writs of attachment and against insolvency applications by the tax office at the competent fiscal court
• Undeclared income from foreign capital assets (e.g. from Switzerland, Liechtenstein, Austria); use of foreign foundations
• Employing sub-contractors using fictitious invoices
• Estimates on grounds of non-submission of tax returns and initiation of enforcement measures by the tax office
• Evasion of income tax and social insurance contributions in the framework of labour leasing and/or use of sub-contractors (especially in the construction industry)
• Suspicious features found in the framework of audits (analysis of control report)