Crypto Tax Advisor for Bitcoin, Ethereum, NFTs & DeFi

Robust crypto tax figures, well-considered strategies, clear data preparation.

Lars Meyer – Tax Advisor Maximilian Klein – Tax Advisor Jonas Zitranski – Tax Advisor

Crypto tax advice for every type of investor

Whether you are a private investor or a company, our specialist crypto tax advice is tailored to your individual needs

Active traders & day traders

Many trades, many platforms. We bring order to your crypto taxes.

  • Multiple exchanges & wallets cleanly consolidated
  • Tax logic for frequent trades mapped correctly
  • Traceable documentation in line with the requirements of the Federal Ministry of Finance (BMF) guidance

Long-term investors

For larger portfolios and long-term strategies, a clear plan is what counts. Whether your gains remain tax-free depends on the holding period for Bitcoin and cryptocurrencies (in German) — we check this for every holding.

  • Optimised structure for holding periods & disposals
  • Strategic planning for transfers of wealth
  • Clear classification of staking & lending

Companies & crypto projects

We support crypto held as business assets, from tokens to DeFi income.

  • Clean separation of private & business assets
  • Processes & records compliant with the German bookkeeping principles (GoBD)
  • Structure for tokens, NFTs, mining & DeFi

Your benefits with our crypto tax advisor team

Benefit from crypto tax experience since 2014 and a three-digit number of crypto cases handled every year

Current crypto case law explained clearly

Clarity for sound decisions

Optimising crypto taxes legally and sensibly

More structure, less risk

An individual strategy for crypto, DeFi and NFTs

Matched to your type of investor

Clear help with complex crypto tax questions

Even with a large number of transactions

GoBD-compliant documentation for trading & DeFi

Properly prepared for the tax office (Finanzamt)

Strong representation and argumentation before the tax office

We take charge of the line of argument

Common challenges with crypto taxes

These are the situations we see most often

Data chaos

  • Many crypto exchanges, wallets, DeFi protocols
  • No consistent transaction tracking

Tax uncertainty

  • Unclear what is tax-free / taxable with crypto (holding period, staking, lending)
  • Fear of errors in earlier years (2021–2023 etc.)

Pressure from the tax office

  • Letters from the tax office / Bitcoin.de / other exchanges
  • Concern about back payments and criminal proceedings

Important note

The earlier you involve us, the more room for manoeuvre you have.

We help you document your crypto activities completely and optimise them for tax purposes before the tax office starts asking questions.

Does this sound familiar?

Let us discuss your crypto situation.

Book an initial consultation

Crypto taxes declared completely and traceably

We take care of data preparation, strategy and the tax return: clear, clean, traceable

Crypto data preparation

  • Choosing the right crypto tax tool (CoinTracking, Blockpit, Koinly)
  • Full-service data preparation by our team

Tax return

  • Private & business crypto investments
  • Making optimal use of tax opportunities

Ongoing crypto tax advice

  • Discussing relevant crypto transactions in advance
  • Support with objection & court proceedings

Crypto tax structuring

  • Structuring future crypto investments optimally
  • Private strategy or larger crypto project

Voluntary disclosures

  • Group information requests (Sammelauskunftsersuchen) & corrected returns
  • Correction of tax returns already filed

Annual financial statements

  • Cash-basis accounts (EÜR) or balance sheets for crypto held as business assets
  • GoBD-compliant crypto bookkeeping

International

  • Relocation advice (Dubai, Portugal, Ireland etc.)
  • Tax structuring of ICOs

Initial consultation

  • Individual assessment of your crypto activities
  • Clarifying open questions & next steps

How we handle crypto engagements

This is what working together looks like in practice

1

Initial consultation & assessment

A short Teams call or phone call to understand your crypto situation and outline a rough roadmap.

2

Data collection & tool setup

Access to your crypto exchanges and wallets, selection of the right software and import of all transactions.

3

Evaluation & tax concept

Calculation of your crypto tax liability, identification of optimisation options and classification of your crypto activities according to the current view of the tax authorities and case law.

4

Ongoing support

Preparation of your crypto tax returns, answering queries from the tax office and strategic updates.

Your crypto tax advisor: why clients trust us

Our team combines more than 10 crypto tax specialists: tax advisors (Steuerberater) with a Big Four background, blockchain analysts, a lawyer (Rechtsanwalt) and business economists

A three-digit number of crypto corrections every year

We know all the pitfalls and what the tax office looks out for

Team members with their own DeFi & NFT investments

We understand the technology and speak your language

Cooperation with specialist criminal lawyers

For voluntary disclosures with penalty exemption, tax advisors and a lawyer (Rechtsanwalt) specialising in white-collar criminal law work hand in hand

Maximilian Klein
Maximilian Klein
Tax advisor (Steuerberater) & crypto expert
"Crypto taxes are complex, but with the right advice they are entirely manageable. We take the uncertainty off your shoulders and make sure you can sleep soundly at night, no matter how many transactions you have made."

What our clients say

Reviews from our clients on Google and ProvenExpert. The reviews are submitted by users directly on the platforms; we reproduce them in full and without selection. Authenticity is verified exclusively by the platforms. As of: September 2026.

Reviews are shown in their original language (German).

„Sehr strukturierte und digitale Abwicklung von Anfang an. Meine Unterlagen wurden klar angefordert, sauber ausgewertet und am Ende hatte ich endlich das Gefühl, steuerlich wieder den Überblick zu haben. Gerade bei Krypto-Themen war die Beratung durch Herrn Klein verständlich und präzise.“
Konrad Zacher
July 2026 · via ProvenExpert
„Ich bin auf Herrn Klein gestoßen, als ich auf der Suche nach einem Experten für das Kryptosteuerrecht war. Ich bin absolut begeistert von seiner Beratung, seiner sympathischen Art und der Zeit, die er sich nimmt. Ich fühle mich verstanden und habe das Gefühl noch viel von ihm lernen zu können, was Krypto und Steuern angeht. Auch das Büro und die Lage sind absolut schick. Empfehle ich von Herzen weiter! 🙏🏼 Beste Adresse für alles rund um Steuern. 😊“
Kristin Schwan
via Google
„Ich bin wirklich sehr zufrieden mit der Steuerberatungskanzlei Klein. Besonders im Bereich Kryptowährungen habe ich eine äußerst professionelle und kompetente Beratung erhalten. Alle meine Fragen wurden stets schnell und verständlich beantwortet. Die Expertise des Teams ist beeindruckend und ich hatte jederzeit einen Ansprechpartner, der mir weiterhelfen konnte. Ganz klare Empfehlung!“
Ugur Parlaksu
via Google

Concrete scenarios from our practice

This is how we have already helped other crypto investors

Case 1

Private investor with 5 exchanges

Situation: Active since 2017, never taxed correctly, now a letter from the tax office.

Solution: Data preparation, corrected returns for 2017–2024, tax liability legally reduced, criminal proceedings avoided.

Case 2

DeFi/NFT-heavy trader

Situation: Thousands of transactions, airdrops, liquidity mining.

Solution: Tool selection, categories cleanly defined, clear documentation for the tax office.

Case 3

Company with crypto held as business assets

Situation: NFT sales + token project.

Solution: Correct accounting, annual financial statements, tax-optimised structure.

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Frequently asked questions for your crypto tax advisor

Answers to the most important questions from our clients

My crypto tax report looks implausible – can you check it?

Yes, reviewing existing tax reports is one of our most frequent assignments. We check whether all exchanges and wallets have been captured, whether your own transfers have been matched correctly and whether the acquisition costs are complete. We clarify typical warning signs such as unusually high gains, negative balances or many unclassified transactions until the report is arithmetically traceable and robust vis-à-vis the tax office (Finanzamt).

When is a specialist crypto tax advisor worthwhile?

A specialist crypto tax advisor is worthwhile even with only a few transactions or if you use several exchanges. At the latest once you have DeFi activities, staking, mining or NFTs, expert advice is essential. Professional support also makes sense if you receive letters from the tax office or want to optimise your tax burden.

Do you also handle earlier tax years / voluntary disclosures with penalty exemption?

Yes, we specialise in corrected returns and voluntary disclosures with penalty exemption (strafbefreiende Selbstanzeige) in the crypto sector. We regularly handle cases dating back to 2017 and work with specialist criminal lawyers where necessary. A timely voluntary disclosure can protect you from criminal consequences.

Which tools do you support (CoinTracking, Koinly, Blockpit...)?

We work with all common crypto tax tools such as CoinTracking, Koinly, Blockpit, Accointing and others. We help you choose the right tool for you, take care of the setup and check the data for plausibility and completeness.

Can you advise me entirely digitally?

Yes, we advise crypto clients from all over Germany entirely digitally. From the initial consultation and data preparation through to the finished tax return, everything takes place online. Personal meetings in Düsseldorf are of course also possible.

How much does crypto tax advice cost?

The costs depend on the scope: the number of transactions, the complexity (DeFi, mining etc.) and whether prior years need to be caught up. In the free initial consultation you receive a transparent estimate. As a rule, we charge in accordance with the German Tax Advisors’ Fee Regulation (StBVV), but we also offer flat fees.

How long does processing take?

The processing time depends on the complexity and the availability of data. We can complete simple cases with well-prepared data within 1-2 weeks. For complex cases covering several years and many transactions, allow 3-6 weeks. Urgent cases are given priority.

What happens if transaction data is missing or an old exchange has closed?

Missing data is a common problem and can be solved in most cases. We reconstruct the history from exchange exports, wallet addresses, transaction hashes, blockchain explorers, emails and bank payments. The aim is to evidence acquisition costs and holding periods as far as possible and to document any remaining assumptions traceably, so that the calculation stands up even to queries from the tax office.

Can I keep my current tax advisor?

Yes. If you wish, we take on only the data preparation and the tax classification of your crypto activities as a clearly defined partial engagement. We make the reviewed results available to your current tax advisor for the income tax return, financial accounting or annual financial statements. We agree the division of tasks clearly before we start, so that no review steps are lost.

Which documents do I need for crypto tax advice?

We need your exchange exports (CSV or API access), a list of your wallet addresses and information on special events (airdrops, forks, lost coins). The more complete and clean your data, the faster and more cost-effectively we can prepare your tax report.

Tax advisor for cryptocurrencies: our services at a glance

As tax advisors (Steuerberater) for cryptocurrencies, we cover the entire chain from the raw data to the tax assessment. The difference from general tax advice lies less in tax law than in the data work: anyone who wants to declare cryptocurrencies properly has to bring together tens of thousands of transactions across exchanges, wallets and protocols before a single tax question can even be answered.

Data preparation

Full exports of all trading venues and wallets used, consolidation, matching of transfers between your own addresses, closing of gaps. This part is handled by our team of tax advisors and blockchain analysts.

Tax classification

Disposals, staking, lending, mining, airdrops, NFTs and derivatives are classified transaction by transaction — this determines which category of income applies and whether the holding period can apply at all.

Calculation and tax return

Calculation of gains using FIFO per wallet, valuation in euros at the relevant point in time, transfer into the schedules of the tax return.

Communication with the tax office

Queries about crypto matters are the rule, not the exception. We answer them with the documents from which the figures originate.

The substantive basics — holding period, exemption limit (Freigrenze), FIFO, staking, DeFi, NFTs — are covered in detail in our crypto tax guide.

Crypto voluntary disclosure and tax criminal law

A considerable share of our crypto engagements does not start with the current tax return, but with years that were never declared. The reason is rarely bad faith: many people assume that only the payout in euros is relevant for tax purposes — in fact, exchanging one cryptocurrency for another is also a disposal.

Since the 2026 reporting period, crypto-asset service providers have been transmitting transaction data automatically to the tax authorities. What is reported and from when is explained on our page on DAC8. For open prior years, this changes nothing about the tax liability — it changes the likelihood that inconsistencies will be noticed.

Whether a crypto voluntary disclosure is still an option depends on timing: once an audit order has been announced, proceedings have been initiated or the offence has been discovered, it is barred. By far the greater part of the work comes before that — in determining the tax bases completely, because an incomplete voluntary disclosure costs you the exemption from penalty entirely, not just in part.

How the roles of tax advisor and lawyer (Rechtsanwalt) are divided and what Section 392(1) of the German Fiscal Code (AO) provides is explained on our page on tax criminal law.

Practical knowledge

What a specialist crypto tax advisor does behind the tax report

What professional work goes into a robust crypto tax return? You will find the general tax rules in our crypto tax guide.

Typical reasons to bring in a crypto tax advisor

  • A tax report looks implausible or transaction data is missing
  • Several exchanges and your own wallets need to be consolidated
  • DeFi or staking transactions are unresolved
  • Earlier tax years are open and a corrected return or voluntary disclosure needs to be considered
  • Queries from the tax office or a planned larger sale are coming up

In these cases it is not enough to transfer a single figure into the tax return: an automatically generated tax report can contain significant errors. A specialist tax advisor therefore checks not only the end result, but also the data and assumptions on which it is based.

Open the full guide

1. A tax report is not yet a reviewed tax return

Crypto tax tools such as CoinTracking, Blockpit or Koinly are valuable aids. They import transactions, assign them to certain categories and calculate gains and losses.

However, a tool does not automatically know the economic background of a transaction.

An outflow from a wallet can, for example, be:

  • a sale,
  • a transfer to one of your own wallets,
  • a bridge to another network,
  • a deposit into a liquidity pool,
  • a payment,
  • a transfer as collateral,
  • a lost holding
  • or an interaction with a smart contract.

If a transfer between your own wallets is mistakenly treated as a sale, a gain may be reported that never arose economically. If the original acquisition costs of a holding are missing, the later capital gain can turn out far too high.

Even a report that looks complete can therefore be wrong. What matters is not only whether all transactions have been imported. The entire history has to fit together logically, technically and for tax purposes.

A tax advisor for cryptocurrencies therefore does not simply adopt the result produced by software. They check whether the data basis is complete, whether transactions have been classified correctly and whether the calculation can be explained traceably to the tax office.

2. How a crypto tax advisor checks the data basis

Capturing all exchange accounts and your own wallets completely

It all starts with a complete inventory.

This includes not only the exchanges and wallets currently in use. Closed accounts, old hardware wallets, earlier smartphone wallets and wallet addresses that are no longer used can also be relevant for the acquisition history of coins sold later.

A specialist crypto tax advisor therefore clarifies, among other things:

  • Which exchanges and brokers were used?
  • Which wallets and wallet addresses belong to the client?
  • Which networks were transactions carried out on?
  • Which DeFi protocols were used?
  • Are exchange exports and API data complete?
  • Are there transactions from earlier tax years?
  • Were coins transferred off-exchange or directly between individuals?
  • Do tax reports or earlier calculations already exist?

A single missing data source can mean that acquisition costs can no longer be allocated or that your own transfers are classified incorrectly.

Reconciling your own transfers and balances

Transfers between your own wallets do not automatically trigger an economic sale. In tax tools, however, they often initially appear as separate transactions: as an outflow on one side and an inflow on the other.

If these two sides are not linked correctly, artificial gains, losses or missing acquisition costs can arise.

We therefore check, among other things:

  • Do the outflow and inflow match in time?
  • Do the coin amount and fees match?
  • Are these really two wallets of your own?
  • Were the original acquisition data carried over?
  • Is a bridge or a change of network involved?
  • Do the calculated closing balances match the actual balances?

Reconciling balances is one of the most important plausibility tests when preparing crypto transactions. If the calculated balances do not match the actual wallet and exchange balances, the calculation of gains is usually not yet robust either.

Classifying technical transactions for tax purposes

Blockchains store technical transactions. The tax return, on the other hand, requires an economic and tax classification.

This translation is particularly demanding with DeFi. A single smart contract interaction can generate several token movements, even though economically there is only one connected transaction.

Typical examples are:

  • swaps via decentralised exchanges,
  • bridges between different networks,
  • wrapped tokens,
  • deposits into liquidity pools,
  • receipt and return of LP tokens,
  • staking and restaking,
  • lending protocols,
  • liquidations,
  • yield farming rewards,
  • airdrops,
  • NFT minting
  • and fees in different tokens.

The software used may recognise each individual transaction. But it does not always reliably recognise which transactions belong together and how they are to be treated for tax purposes.

An experienced crypto tax advisor therefore combines technical understanding with a tax assessment of the actual facts.

Reconstructing missing acquisition costs

Missing acquisition costs are among the most common causes of excessive crypto gains.

The problem arises, for example, when:

  • an earlier exchange was not imported,
  • coins come from a wallet that was not captured,
  • one of your own transfers was treated as income,
  • an exchange export covers only part of the period,
  • tokens lost their history through a swap or a bridge
  • or earlier transaction data is no longer directly available.

In such cases, the origin of the holding has to be reconstructed as far as possible. For this purpose, exchange exports, wallet histories, transaction hashes, blockchain explorers, emails, bank payments and earlier tax reports can be cross-checked.

The professional work is therefore not limited to an automatic calculation. First, it has to be ensured that the calculation bases used are complete and plausible.

3. Typical warning signs in a crypto tax report

Anomaly Possible cause
Unusually high gain Missing acquisition costs or acquisition costs recorded as zero
Many unknown receipts Your own transfers were treated as incoming funds
Negative coin balances Missing purchases, wrong order or incomplete imports
Closing balances differ significantly Wallets are missing or transactions were imported twice
Many unclassified transactions DeFi, bridge or smart contract transactions
Gains from mere wallet changes Your own transfers were recognised as sales
Different results in each tool Diverging classifications, price data or calculation methods
Missing history after a bridge The outgoing and the incoming transaction were not linked

Individual warnings do not automatically mean that the whole report is wrong. They do, however, show where a professional review is needed.

4. Practical examples from our work

Practical example: several exchanges and missing acquisition costs

An investor had been active on various centralised exchanges for several years and had regularly transferred his holdings to his own wallets. A crypto tax tool was set up for the first time for the current tax return.

After the import, the report showed an unusually high taxable gain. At the same time, the evaluation contained numerous holdings without acquisition costs and several wallet inflows classified as income.

The review revealed:

  • An exchange used in the past was missing entirely.
  • Several transfers between his own wallets were not linked.
  • An old exchange export contained sales, but not the original purchases.
  • Fees were in part treated as separate disposals.
  • Some stablecoin transfers had been imported twice.

The missing data was supplemented from exchange exports, wallet addresses and blockchain transactions. Own transfers were then merged, duplicates removed and the balances reconciled again.

Only after this clean-up could a plausible tax report be prepared.

The decisive point: it was not a special tax arrangement that changed the result. What mattered was that the actual transaction history was reflected completely and correctly.

Practical example: DeFi activities across several networks

Another case involved swaps, liquidity pools, bridges and staking on several EVM-compatible networks.

The tax tool had automatically imported most of the transactions. However, the report contained numerous transactions that were not classified or classified incorrectly.

Among other things:

  • bridge transactions were treated as sales and repurchases,
  • LP tokens were recorded without a link to the original pool deposit,
  • staking deposits were classified as outflows of assets,
  • rewards were imported several times
  • and gas fees were not taken into account consistently.

Processing the data line by line would not have been sufficient. First, the protocols used and the economic processes had to be identified.

Then related smart contract interactions were grouped and comparable transactions treated consistently. Uncertain or manually adjusted items were documented so that the work can still be traced later.

The result was not just a new tax report. A consistent methodology emerged that could also be used for the following tax years.

The practical examples are anonymised and simplified for clarity. The tax treatment always depends on the specific facts of the case.

5. Open prior years, corrected returns and possible voluntary disclosure

Particular caution is required if crypto activities relevant for tax purposes were not declared, or possibly declared incompletely, in earlier returns.

In this situation, you should not rush to submit a single figure to the tax office. First, the following needs to be clarified:

  • Which tax years are affected?
  • Which transactions have not yet been taken into account?
  • Is the historical data still fully available?
  • Which gains, losses and other income actually result?
  • Has the tax office already asked any questions?
  • Have tax assessments already been issued for the years concerned?
  • Is a simple correction possible, or does a possible voluntary disclosure need to be examined?

Whether a correction is required and in what form depends on the specific facts. The complete transaction data should therefore be prepared first and the tax returns concerned reviewed.

You will find further information on this topic on our page on the DAC8 risk check and crypto voluntary disclosure. The legal requirements for a voluntary disclosure to the tax office – its effect under Section 371 of the German Fiscal Code (AO), the grounds that bar it and the completeness requirement – are covered there separately.

6. What a crypto tax advisor should document

The result of the work should not consist merely of a single profit figure.

Depending on the engagement, the following components should be available:

A complete overview of the data sources

It is documented which exchange accounts, wallets and DeFi protocols were included in the evaluation and which networks were involved.

A cleaned-up transaction history

Duplicates, missing data, unclear transfers and unclassified transactions have been reviewed and corrected as far as possible.

A tax report checked for plausibility

Balances, acquisition costs, gains and losses are arithmetically traceable. Significant anomalies have been clarified.

Documented assumptions

Manual corrections and professional decisions were not only changed in the tool, but also justified and documented.

Usable documents for the tax return

The results are prepared in such a way that they can be transferred into the tax return or the annual financial statements and explained if questions arise.

Records suitable for archiving

Exports, wallet lists, reports and relevant additional documents are stored in an orderly way. This means the history does not have to be completely reconstructed again if questions arise later.

7. Why a crypto tax advisor makes sense before larger transactions

Many investors only have their situation reviewed after the end of the tax year. Reports can then be checked and errors corrected. The economic transaction itself, however, has already been completed.

Before a larger sale or an extensive reallocation, on the other hand, important questions can still be clarified:

  • Which specific holdings are to be sold?
  • Are the acquisition data for these holdings complete?
  • Which transactions have already been realised in the current year?
  • Are there open losses or unresolved holdings?
  • Are private and business wallets clearly separated?
  • Which documentation should be secured before the transaction?
  • What consequences does the transaction have for later tax years?

Especially with larger portfolios, a specialist tax advisor should therefore be involved before implementation wherever possible. The tax consequences should be known before a transaction is carried out that can no longer be reversed.

8. Crypto tax advice as a clearly defined partial engagement

It is not always necessary to change your current tax advisor.

Our firm can take on only the data preparation and the tax classification of your crypto activities. The reviewed results are then made available to your current tax advisor for the income tax return, financial accounting or annual financial statements.

Before starting, the following should be clearly agreed:

  • Who obtains the raw data?
  • Who prepares and reviews the tax report?
  • Who assesses individual tax questions?
  • Who submits the tax return?
  • Who answers queries from the tax office?

A clear division of tasks prevents important review steps from getting lost between the tax tool, data preparation and the traditional tax firm.

If the crypto assets are held as business assets, different rules apply than for private assets — in particular, the one-year holding period does not apply there. What this means for the balance sheet and financial statements is explained under crypto bookkeeping and annual financial statements (in German).

9. How to recognise a specialist crypto tax advisor

A specialist tax advisor should do more than simply pass on a software report.

In particular, look at whether the tax advisor:

  • captures all exchange accounts used and your own wallets,
  • understands the technical processes of DeFi and smart contracts,
  • checks balances and your own transfers for plausibility,
  • does not accept missing acquisition costs without scrutiny,
  • cross-checks different data sources,
  • documents manual corrections traceably,
  • can explain the methodology used in an understandable way,
  • takes into account the effects on other tax years
  • and remains available if the tax office has queries.

What matters is not whether a firm uses every available crypto tool. What matters is whether it can critically review the results, classify them professionally and defend them before the tax office.

10. Which page is the right one for your concern

Would you first like to understand when a sale, an exchange, staking or other crypto activities become relevant for tax purposes? Read our crypto tax guide.

Would you first like to get a rough estimate of your possible tax burden? Use our crypto tax calculator.

Have you not declared earlier crypto activities, or possibly declared them incompletely? Find out about our DAC8 risk check and crypto voluntary disclosure.

Do you need complete preparation of your transaction data, a review of an existing report, support with open tax years or a professionally supported crypto tax return? Then a specialist crypto tax advisor is the right point of contact.

A crypto tax advisor for traceable and robust results

A good crypto tax advisor does not start with a figure in the tax return. First, it has to be clarified whether the data is complete, whether technical transactions have been understood correctly and whether the calculation used can still be traced later.

Only when the data basis, tax classification and documentation fit together is the result robust.

Have your crypto situation reviewed

We get an overview of your exchange accounts, your own wallets, previous tax reports and any open tax years. We then clarify which next steps make sense for your case.

Book an initial consultation

More than just crypto: our other specialisms

Discover our other areas of expertise

Influencers & content creators

Tax advice for social media personalities, agencies and personal brands, from brand collaborations to international assignments.

More on taxes for influencers →

International tax law

Moving abroad, moving to Germany and cross-border income, from exit tax to double taxation agreements.

More on international tax law →

Inheritance & gifts

Transferring wealth in a structured way, including real estate, company shares and cryptocurrencies.

More on inheritance & gift tax →

Next step

Looking for a crypto tax advisor? Request an initial consultation

We assess how we can best support you with data preparation, your tax return or a voluntary disclosure.

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