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Heiko Stoll has more than 20 years'experience in national and international tax law, including international tax such as double tax treaties, cross-border withholding tax, German CFC rules and real estate taxation, in particular real estate transfer tax. His practice focuses on the structuring and tax optimisation for closed-ended and open-ended funds as well as on tax advice and tax due diligence to fund investors, tax optimisation of investment structures. Furthermore, he advises on corporate taxation and transaction-related tax advice (corporate and real estate transactions, conversions). Heiko offers special tax advisory services, e.g. on tax issues in relation to securities lending and repurchase transactions and structured financial products, as well as on tax compliance / DAC6 (reporting obligations in relation to cross-border tax arrangements). Other mainstays of his practice include private equity and venture capital tax issues, tax advice on restructurings and tax optimisation of corporate group structures, as well as tax advice vis-à-vis (tax) authorities and assistance in the context of tax litigation.


  • 2021: Heiko is one of (only) 44 so-called “Ranked Lawyers”: ranked in Band 5 with the following content: ´Heiko Stoll is considered a "delight" by one interviewee, who finds that his "input is always clear and robust." He acts for investors on the tax structuring of funds and transactions.´
  • 2020: „Clients appreciate Heiko Stoll for his "focused, directional advice." He assists with securities taxation and the structuring of investments and is active on group restructuring matters. His clients include investment companies, funds and international corporations. He also focuses on providing regulatory, corporate tax and fund structuring advice to asset management and financial services companies.“


Professional Affiliations

    • International Fiscal Association (IFA)
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  • Stoll, Heiko / Schuh, Martin: Kommentierung von §§ 4,8,11,15 InvStG in Baur/ Tappen, Investmentgesetze, 3. Auflage, 2015.
  • Stoll, Heiko / Schuh, Martin: Eigenkapitalinvestments ausländischer Fondsgesellschaften – Besteuerung im Nicht-DBA-Fall, in: Betriebs-Berater (BB) 2011, 2330-2335.
  • Schmid, Hubert / Stoll, Heiko: Zweifelsfragen bei der Auslegung von § 19 Abs. 3 GewStDV, in: Betriebs-Berater (BB) 2005, 582-587.
  • Stoll, Heiko / Mühlhäuser, Felix: Besteuerung von Wertpapierdarlehensgeschäften und Wertpapierpensionsgeschäften, in: Deutsches Steuerrecht (DStR) 2002, 1597-1602.
  • Schmid, Hubert / Stoll, Heiko: Steuerliche Behandlung des echten Wertpapierpensionsgeschäfts nach dem Dividendenstripping-Urteil des BFH, in: Deutsches Steuerrecht (DStR) 2001, 2137-2144.