Florian has more than 25 years of experience advising international companies, banks and financial investors on tax matters relating to M&A, private equity and structured finance transactions as well as financial products and alternative investments.
Prior to joining the firm in 2023, Florian practiced at two other leading international law firm for more than two decades. In recent years, besides his transactional work, he has increasingly worked on internal investigations in the financial sector, particularly with dividend arbitrage transactions. He also has represented domestic and international banks in tax-related civil law litigations with counterparties. Florian is recommended as a tax lawyer in Germany in several leading legal directories.

Experience

Representative matters

  • Corestate Capital Holding S.A., an investment manager and co-investor with €13.2 billion of core assets under management, on its successful restructuring.
  • PAI Partners on the acquisition of a majority stake in Infra Group, a service provider in the infrastructure sector.
  • Nimbus on the sale of Extrusuion Technology Group to Davis-Standard LLC.
  • Palero on the acquisition of Tech Power Electronics Group from Schwa-Medico Group.
  • Numerous domestic and international financial institutions on contentious and ongoing tax matters related to their equities and derivatives transactions.

Published Work

  • Publication "Status quo: fund structures and CFC taxation", RdF 2023, 47
  • Publication “"Fund structures and CFC taxation – update to RdF 2023, 47", together with T. Spranger, RdF 2023, 47
  • Publication "Federal Tax Court: ruling on exit taxation in case of securities lending (ruling dated 23 November 2022, I R 52/19]", RdF 2023, 233
  • Publication "Federal Tax Court: ruling on tax balance sheet treatment of contributions under the leasing residual value model (ruling dated 13 September 2023 – XI R 20/20)", BB 2024, 496

Speaking Engagements

  • Lecture at seminar Steuergipfel 2023 #NextGeneration on “Überblick: Aktuelle Entwicklungen bei Finanzierungstransaktionen / Substanz“ [Overview: current developments regarding financing transactions / substance], together with G. Breuninger, Düsseldorf, March 2023
  • Seminar on taxation of Joint Ventures, Forum Transaktionen im Steuerrecht, together with H. Weber, Frankfurt, June 2023
  • Lecture at annual withholding tax seminar of the German Foreign Banking Association on “KESt-Erstattungsanträge im Aktienhandelsgeschäft und wirtschaftliches Eigentum“ [WHT reclaims relate to stock trading and tax ownership”, together with L. Exner, Frankfurt, September 2023
  • Online seminar “Hinzurechnungsbesteuerung und Fondsstrukturen nach dem neuen BMF-Schreiben“ [CFC taxation and fund structures accordin to the new administrative guidance], together with T. Spranger, September 2023
  • Lecture at conference Betriebsprüfung zwischen Steuerstreit und Strafrecht on „Top Themen in der BP“ [Key topics in tax audits], Frankfurt, October 2023
  • Video Podcast “BB im Gespräch mit Florian Lechner, Partner bei Allen & Overy” on tax changes regarding management participations under the German Future Financing Act, November 2023 
  • Client webinar on developments in German real estate transfer tax law, together with F. Lechner and T. Spranger, November 2023
  • Panel member at IBA 13th Annual London Finance and Capital Markets Conference “Current developing issues in cross-border finance”, London, January 2024
  • Seminar on tax implications of real estate financing at Forum für Kapitalmarktinstrumente, Vienna, January 2024
  • Finanzinstrumentetag 2024 – Steuer- und Bilanzrecht

Leadership Positions And Professional Affiliations

  • Verband der Auslandsbanken: Member of the Capital Gains Tax Expert Advisory Board
  • Forum Kapitalmarktinstrumente - Kapitalmarktfinanzierung e.V. - Member of the Executive Board
  • Forum Transaktionen im Steuerrecht e.V. - Member

Recognition

Tax Leading Names
Legal 500 Germany 2024
Florian Lechner … is renowned for his tax expertise within the banking and finance sector, with a strong track record of advising across multi-jurisdictional M&A, regulatory compliance, tax investigations and fiscal disputes.
Chambers Germany Tax – Band 3

Qualifications

Admissions

Admitted as German Rechtsanwalt, 1998

Academic

Second German Law Degree, State of Bavaria, Germany, 1998

First German Law Degree, University of Munich, Germany, 1995

Disclaimer
A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.