Specializes in the taxation of high-net-worth individuals
Hamburg
@alvarezmarsal
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Christian Röpke is a Senior Director with Alvarez & Marsal Tax in Hamburg.
With more than 18 years of experience in employment taxes, Mr. Röpke specializes in rewards and taxation of high-net-worth individuals, in particular with respect to management equity programs, carried interest schemes, co-investment arrangements and the taxation of executives within the private equity sector.
Mr. Röpke has worked with clients across various industries and has led a tax team of employment tax and rewards specialists, advising clients domestically and across regions.
Prior to joining A&M, Mr. Röpke was a Tax Director with Deloitte, where he advised private equity firms, multinationals and high-net-worth individuals on national and international income tax and employment tax matters. Previously, he worked at PricewaterhouseCoopers, with a strong focus on reward topics.
Mr. Röpke earned a bachelor’s degree in business law (Diplom-Wirtschaftsjurist (FH)) from the Leuphana University of Lüneburg. He has studied business law in Germany and Poland, with a focus on taxes and accounting. Mr. Röpke is a Chartered Tax Advisor in Germany.
Disguised employment (“Scheinselbstständigkeit”) remains a persistent issue in the German labor market. This is reflected not only in the growing number of solo self-employed individuals, but also in the increasing scrutiny by German tax and social security authorities. Disguised employment refers to situations where individuals are formally engaged as independent contractors or freelancers but, in practice, perform their work under conditions similar to those of regular employees.
Thus, understanding the complexities of German tax and social security rules on disguised employments is crucial in M&A deals, as this can often lead to compliance risks and significant financial exposure for the buyer.
After confirming the tax treatment of carried interest in trading fund structures with its decision dated 11. December 2018, Germany’s Supreme Tax Court (BFH) also recently had to decide on the tax treatment of carried interest in non-trading, purely asset managing fund structures.. Even though the BFH referred the case back to the Lower Tax Court of Munich for a final decision due to procedural errors, it already provides clear guidance as to how carried interest is to be qualified for German tax purposes.
Germanys Supreme Tax Court (BHF) recently published two decisions dealing with the income tax treatment of Management Equity Plans (MEP), in which the court confirmed its established case law.
Effective 1st January, 2024, the German legislator has further improved the tax environment for employee share plans as part of the Future Financing Act (“Zukunftsfinanzierungsgesetz”). The updated law includes, inter alia, an extended tax deferral period for employee shares in start-up companies, and an increase of the tax allowance for a so called “all-employee equity plan” to € 2.000.
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Disguised employment (“Scheinselbstständigkeit”) remains a persistent issue in the German labor market. This is reflected not only in the growing number of solo self-employed individuals, but also in the increasing scrutiny by German tax and social security authorities. Disguised employment refers to situations where individuals are formally engaged as independent contractors or freelancers but, in practice, perform their work under conditions similar to those of regular employees.
Thus, understanding the complexities of German tax and social security rules on disguised employments is crucial in M&A deals, as this can often lead to compliance risks and significant financial exposure for the buyer.
