SMP

Michael specializes in fund structuring, advising private-equity and venture-capital funds and their investors on all matters of tax and regulatory law. In addition, he advises on matters of general tax, with a particular focus on international tax law.

Education and Career

Michael studied international business law at the University of Erlangen-Nuremberg and the University of Cambridge. Subsequently, he was a research assistant to Prof. Dr. Ismer (chair of tax law, University of Erlangen-Nuremberg) and a visiting researcher at the Oxford University Centre for Business Taxation as well as at Harvard Law School (as a Fulbright scholar). Michael joined SMP as a research assistant at the time of the firm's formation and then went on to complete his practical legal training at the Higher Regional Court of Berlin, which included stints at SMP and at the tax department of the German Federal Ministry of Finance.

Michael regularly publishes on matters of international tax law.

 

 

 

  • Art. 4 OECD MC (Residence)
    in: Vogel/Lehner, DBA (Double-taxation treaties), 7th ed. 2020 (together with Roland Ismer) (forthcoming) [in German]
  • VAT exemption of the management fee charged by typical private-equity/venture-capital funds
    RdF (›Law concerning financial instruments‹ [journal]) 2018, pp. 312–319 (together with Jens Kretzschmann) [in German]
  • "Cum/Ex dealings" with a domestic [= German] depositary bank on the seller side: Does the depository bank's liability take precedence over the revocation of the administrative decision regarding the tax credit?
    DStR 2017, pp. 905–912 (together with Christian Jehke) [in German]
  • Withholding taxes on royalties and intercompany dividends – Recommendations regarding Germany's tax-treaty policy
    Richard Boorberg publishing house, Münchener Schriften zum Finanz- und Steuerrecht (›Munich Papers on Financial and Tax Law‹), Vol. 7, 2015 (together with Roland Ismer, Rainer Haselmann, Ashok Kaul, Martin Ruf and Sophia Piotrowski) [in German]
  • Rethinking Article 19 OECD MC (Government Service): A Provision in Search of a Rationale?
    Intertax 2015, pp. 245–254 (together with Roland Ismer)
  • Article 19 OECD-MC (Government Service)
    in: Reimer/Rust (eds.), Klaus Vogel on Double Taxation Conventions, 4th ed. 2015 (together with Roland Ismer)