“Every family is shaped by its own unique values and goals—there is no one-size-fits-all solution. That's why I look beyond legal and tax issues to develop sustainable structures that truly reflect a client’s DNA.”

Dr. Maren Gräfe has a strategic perspective, thinking beyond the confines of law and taxation to address the economic and familial consequences of her clients’ decisions. Through her extensive and interdisciplinary network, she has learned to look beyond immediate questions and to integrate secular developments and future-oriented topics into her advisory approach. There is no “one-size-fits-all” solution—what matters are the client’s personal, financial, and family objectives. Any proposed solutions must also fit the client’s DNA and values. For someone who still wants to invest in a highly entrepreneurial and dynamic way, simply opting for a premature transfer of assets to save taxes (and thereby losing certain financial freedoms) is not necessarily the best option. At the very least, alternative strategies are available.

In situations of familial conflict, Ms. Gräfe is particularly keen on finding empathetic and sustainable solutions that help bridge family divides. She collaborates with mediators and, if necessary, psychologists to achieve these aims.

• Tax and Legal Succession Planning
• Corporate Law and Shareholder Disputes
• Single Family Office and Investment Structuring
• Family Governance and Owner Strategy
• Taxation of Complex Private Equity Investments and Investment Income
• Exit Taxation Advice
• (International) Foundation Structuring

• Hamburg Bar Association: 2007

• Berlin Chamber of Tax Consultants: 2010

(For confidentiality, client types or cases are generalized, e.g., “private client, executive of Fortune 500 company.”)

1. Advising Founders on an Exit/Company Sale and Setting Up Family Office Structures
   • Establishment of family foundations to prepare a tax-efficient and strategically aligned sale structure. Supported the setup of three foundations (including drafting individual articles of association), coordinating with the foundation supervisory authority, and transferring company shares. Developed articles that accounted for a potential sale scenario, crafted the relevant transfer agreements, and created governance frameworks for using the foundations as family offices post-sale. Ongoing legal counsel for the foundations (organizing meetings, preparing minutes, maintaining a family register) and collaboration with external tax advisors on specific compliance issues. After the sale, devised a tax-efficient investment strategy and set up Family Office structures.
2. Advising a Branch of a Larger Family Enterprise
   • Establishing and managing an ongoing inheritance tax screening for a large family enterprise (evaluation of relief options and administration quota). Revised the wills of a shareholder branch to avoid latent risks of triggering hidden reserves. Additionally, identified opportunities for tax-efficient early inheritance (already significant private assets) among various children and implemented measures (family partnerships). The senior family member plans to contribute his remaining shares to a charitable foundation. GRÄFE Tax & Legal provides both tax and legal support for this process, including guidance on charitable law implications and making necessary amendments to the foundation’s charter in coordination with the foundation supervisory authority.
3. Senior Member of a Large Family Business Group
   • Comprehensive succession planning for a large family enterprise: analysis of inheritance tax relief under Sections 13a/b ErbStG across the entire group (over 100 companies). Considered restructuring the balance sheet to optimize inheritance tax and explored opportunities to place the group into a new family structure to avoid exit taxation. Drafted new succession and enduring power of attorney documents. Structured both private and investment assets, leveraging tax advantages for spouses (including marital property arrangements such as “Güterstandsschaukel” and housing concepts). Restructured international assets to avoid double taxation. Facilitated fair distribution within the family, including moderation and compensatory measures. Resolved unrecognized gift tax issues within the family.
4. High Net Worth Individual/Entrepreneur with a Single Family Office and Holding Company (including retained shares in an operating business), Approx. EUR 500 Million in Assets
   • Prepared emergency documents (entrepreneur’s will, powers of attorney, living wills) to balance personal and strategic considerations and inheritance tax opportunities, paying special attention to patchwork family situations. Planned potential structural changes to simplify the holding and corporate structure and to utilize inheritance tax relief on business assets. Designed measures for tax-efficient early inheritance, including the option of establishing one or more family foundations (to secure a functioning Family Office and asset management after the principal’s passing and to avoid exit taxation in the event of death). Implemented marital property arrangements to facilitate tax-free asset transfers between spouses. Provided ongoing support for various projects (structuring a classic car collection, acquiring assets abroad to avoid double taxation, cross-border entrepreneurial activities). Partly restructured Family Office cost-sharing to avert tax pitfalls. Took over ongoing tax advisory (tax returns, annual financial statements, VAT returns, payroll tax) for about ten entities (GmbHs, GmbH & Co. KGs, and partnerships) and six family members, setting up a cash management system and a tax compliance management system in close collaboration with the Single Family Office staff.
5. Entrepreneurial Family with Operating Company and Single Family Office (Enterprise Value Over EUR 4 Billion; Private Wealth Over EUR 70 Million in Real Estate, Securities, and Significant VC/PE Investments with High Growth Potential)
   • Prepared emergency documents (entrepreneur’s will, powers of attorney, living wills). Assisted the family (in collaboration with their Family Officer and current tax advisor) in avoiding a substantial inheritance tax event upon death. Implemented preventive will arrangements, as well as planning and executing the shielding of private assets and PE/VC shareholdings. Established a German family foundation as a new holding company and Single Family Office platform. Created suitable family governance guidelines and reviewed marital property issues. Evaluated the gradual, tax-optimized transfer of shares in the operating company, if necessary with usufruct structures. Performed inheritance tax analysis under Sections 13a/b ErbStG and assessed possible structural accounting measures to improve the initial position. Supported the next generation’s involvement in the operating business alongside Dr. Karin Ebel (ebel&team GmbH).

Publications, Lectures, and Activitiesby Dr. Maren Gräfe

I. Articles / Contributions

• www.BDO.de, July 2020: “COVID-19: Corona Pandemic as a Stumbling Block for (Planned and Completed) Business Successions – No Relief from the Legislator?”
• www.BDO.de, June 2020: “Exit Tax – Stricter Tax Rules for International Entrepreneurial Families and Companies? Who Is Affected?”
• DUB Unternehmermagazin, August 2020 (pp. 78–79): “Well-Prepared for All Eventualities”
• Private Banking Magazin, January 14, 2020: “Business Succession Subject to Usufruct Is Back”
• ZEV 2019, p. 79: “The 2019 ErbStR in Tension with the 2019 ErbStR: Deviations, Clarifications, and Contentious Issues in the Area of Business Succession”
• Newsletter INSIGHT 02/2020, published by PETER MAY Family Business Consulting: “New Tax Burdens Threaten International Entrepreneurial Families”
• PLATOW Recht, No. 131 (November 13, 2019): “Succession Planning – Renaissance of the Family Foundation” (together with Berndt Zinnöcker and Herbert Bischof)
• Financial Planning Magazin, Issue 02/2019: “Emergency Planning for Inheritance and Gift Tax, Even Without an Actual Gifting Event”
• Private Banking Magazin: “Why Caution Is Advisable with Club Deals” (together with Prof. Brück)
• ERbStB 2018, p. 145: “Cryptocurrency Transactions – Distinguishing Between Commercial Activity and Private Asset Management, and Other Issues from the Investor’s Perspective” (together with Kanders and Thonemann-Micker)
• Private Banking Magazin: “Tax Pitfalls and Structuring Options in Cryptocurrency Trading”
• ZEV 2018, p. 325: “Changes in French Wealth Taxation”
• ZEV 2017, p. 471: “Structuring Considerations for the Transfer of Business Assets Subject to Usufruct” (together with Kraft)
• ZEV 2017, p. 669: “Determining the Remotest Beneficiary in an Inter Vivos Foundation Arrangement” – Discussion of FG Münster, judgment dated May 18, 2017 – Case No. 3 K 3247/15 Erb (together with Pascher)
• ZEV 2017, p. 471: “Reserved Usufruct Prevents the Tax-Neutral Gratuitous Transfer of a Business” – Discussion of BFH, judgment dated January 25, 2017 – Case No. X R 59/14 (together with Kraft)
• INTES Unternehmerbrief 01/2017, pp. 16 ff. and 02/2017, pp. 14 ff.: “Inheritance Tax – The Incalculable,” Parts I and II
• Private Banking Magazin, October 2016: “The Inheritance Tax Reform Is Coming – A Complete Zero-Tax Scenario Will No Longer Exist” (together with Huber)
• Private Banking Magazin, July 2016: “Foundations and Family Offices in Focus – Effects of the 4th EU Money Laundering Directive” (together with Schulz)
• Private Banking Magazin, April 2016: “Why Investors Must Declare Foreign Currency Accounts Themselves” (together with Schulz)
• INTES Unternehmerbrief, Issue 02/2016, p. 18: “Structuring Family Assets – The Tax Perspective”
• ISR 2016, pp. 219 ff.: “Anti-Abuse Clauses: The Relationship Between General and Specific Anti-Abuse Clauses – Illustrated Using Structures with Foreign Family Foundations”
• IWB 10/2016, pp. 364 ff.: “Salvaging Fictitious Capital Losses in Corporate Shareholdings Upon the Relocation of Natural Persons” (together with Kraft)
• “Succession Planning in Practice” (together with Klümpen-Neusel) in:
  Kohlbeck/Rabbe/Haas (2014): Factors Influencing Succession in Family Businesses (Equa publication series)
• “Inheritance and Gifts: Use Tax Advantages Now,” in: Endres, Tax Changes 2013/2014 (Haufe)
• Stiftungsmagazin of BW Bank, Issue 2014: “Investment Options for Charitable Foundations – Investing in Corporate Shareholdings” (together with Klümpen-Neusel)
• Vermögen & Steuern, 2012 Issue 4, p. 34: “White Money Strategy in Switzerland” (together with Patkòs)
• ZEV 2012, p. 203 – Country Report: “Switzerland: Tax Agreement with Germany”
• FAZ, September 21, 2012: “Transferring Real Estate Without Gift Tax” (together with Lehnen)
• BankPraktiker – WIKI (Finanz Colloquium Heidelberg) 2012: “Asset Succession Planning and Foundation Management: Legal and Tax Aspects” (together with Klümpen-Neusel)
• Vermögen & Steuern, 2012 Issue 3, p. 18: “Family Foundations as a Possible Solution: When Private and Corporate Assets Are Mixed” (together with Hecht)
• DStR 2012, p. 65: “The Treatment of Mixed Gifts and Gifts Subject to Conditions According to RE 7.4 ErbStR 2011”
• Vermögen & Steuern, 2011, p. 36: “Courses of Action for German Bank Clients in Switzerland – The Germany–Switzerland Tax Agreement” (together with Hecht)
• ZEV 2010, p. 601: “Implications of Retention Requirements for Corporate Assets Following the Inheritance Tax Reform”
• DB 2008, p. 1251: “Legal Protection in Enforcement Proceedings” (together with Hecht/Jehke)

II. Commentaries & Books

• Handbuch Professionalisierung von Familienvermögen (together with Karin Ebel & Corinna Schulthess Traumüller, ESV Verlag – forthcoming)
• Beck’scher Online Commentary on the ErbStG (eds. Erkis/Thonemann-Micker, 4th ed.): Commentary on §§ 15 & 21 ErbStG (since 2018)
• “The Special Context of Leadership Roles in Family Businesses” (together with Schween), in: May/Bartels, Governance in Familienunternehmen (Bundesanzeiger Verlag 2017)
• “Succession and Emergency Planning for Executive Management and Supervisory Boards,” in: May/Bartels, Governance in Familienunternehmen (Bundesanzeiger Verlag 2017)
• “The International Entrepreneurial Family – A Special Kind of Challenge” (together with Jeschke), in: May/Bartels, Die Nachfolge in Familienunternehmen (Bundesanzeiger Verlag, 2015)
• Strahl, “Income Taxes – Problem Areas in Tax Consulting”: Commentary on “Accretion” (since 2008)
• “Squeeze-Outs under German, French, and Spanish Corporate Law. An Economic and Comparative Legal Analysis Taking into Account European Legal Harmonization” (Doctoral dissertation under Prof. Dr. Dr. h.c. Theodor Baums at Johann Wolfgang Goethe University, Frankfurt am Main)

III. External Lectures and Specialist Events

• May 2021: 23rd finanzebs FORUM, May 7–8, 2021 in Cologne: “Asset Protection – An Exchange of Experiences”
• May 2021: BDO Webtalk “Generational Succession in Family Businesses – An Exchange of Experiences” with guests Dr. Reinhardt Zinkann (Miele) and Prof. Dr. Nadine Kammerlander (WHU)
• December 2020: Bayerischer Mittelstandstag 2020: “Current Challenges at the Interface Between the Entrepreneurial Family and the Family Business,” together with Andreas Winter
• December 2020: BDO WebTalk “Success Factors for Family Businesses in Times of Crisis” with guests Prince Felix zu Salm-Salm (entrepreneur) and Stefan Heidbreder (Stiftung Familienunternehmen)
• July 2020, FBN Online Roundtable (with entrepreneurial families): “Inheritance Tax – Challenges for Family Businesses”
• September 2020: 9th Frankfurt Financial Planner Forum: “Current Insights from Consulting on Asset, Succession, and Ownership Structures”
• January 2020: Financial Planner e.V. / International Bankers Forum Luxembourg: “Current Developments in Asset and Succession Structuring – With a View to the DACH Region”
• November 2019: Lecture at the Wealth Managers’ Forum Switzerland on issues of international asset structuring and tax planning
• 2018/2019 ZEV Annual Conference (speaker and panel member): “Tax Pitfalls in the Relationship Between a Corporation, Its Shareholders, and Related Parties”
• November 2018 (with the Association Erben & Verschenken and LGT Liechtenstein) at the Kaufmanns-Casino: “Real Estate as an Asset Securing Across Generations” (with external speakers such as Thomas von Tucher)
• October 2018: “Taxation of Crypto Investments” (Donner & Reuschel Crypto Workshop)
• October 2018: “Emergency Inheritance Tax Planning for Family Businesses” (Finanzebs Summit)
• May 2018: FPL e.V. Luxembourg / IBF Luxembourg – “Tax Pitfalls and Structuring in Cryptocurrency Trading”
• November 2017: Joint client event with Berenberg Bank in Munich: “Emergency Inheritance Tax Planning for the Entrepreneur”
• January 2017: FPL e.V. Luxembourg / IBF Luxembourg – “Inheritance Tax Reform – New Parameters for Transferring Businesses to the Next Generation”
• November 2015: Foundation Workshop at TU Munich (Prof. Dr. Dr. Achtleitner, Prof. Dr. Block, Dr. Rupert Graf Strachwitz): “The Renaissance of the Double Foundation and the Upcoming Inheritance Tax Reform”
• November 2015: Estate Planner Days of VEPD in Wiesbaden: “The EU Succession Regulation and Its Impact on Succession Planning”
• June 2015: FPL e.V. Luxembourg / IBF Luxembourg – “Consequences of the Federal Constitutional Court’s Ruling on Inheritance Tax and the Effects of the EU Succession Regulation”
• October 2015: Know-how Day of FPL e.V. Luxembourg / IBF Luxembourg: “Real Estate Assets Before and After the Inheritance Tax Reform”
• January 2014: FPL e.V. Luxembourg / IBF Luxembourg – “Advising German Private Clients in the Area of Tension Between Information Exchange and the New Tax Environment After the Federal Elections”
• August 2013: ASU/BJU Hamburg – “Is the German Mittelstand Threatened with a Loss of Substance? The Impact of Wealth Tax Plans and a Possible Inheritance Tax Reform”
• April 2013: Finanzeps Munich/bestadvice – “The Revival of the Wealth Tax and Its Impact on Wealthy Individuals”
• December 2012: Finanzeps Munich/bestadvice – “Annual Tax Act 2013 – Tax Challenges for Private Investors in Terms of Asset Investment and Structuring in 2013” (together with Lehnen)
• June 2012: Appenzeller Kantonalbank: “Germany–Switzerland Tax Agreement: What Are the Tax and Legal Implications for Swiss-Based Companies and Their Boards of Directors?”
• June 2012: Bar Association of St. Gallen – “Germany–Switzerland Tax Agreement – Unresolved Problems Using the Example of the German Add-Back Taxation”
• May 2012: Financial Planner Luxembourg / IBF Luxembourg – “Germany–Switzerland Tax Agreement – Effects on Luxembourg as a Location”
• April 2012: Yin/IFA (Basel): “Germany–Switzerland Tax Agreement: What Are the Tax and Legal Consequences for Swiss-Based Companies and Their Boards of Directors?”
• March 2012: Zug Trustees’ Association (ZTV) – “Germany–Switzerland Tax Agreement”
• May 2009: TaxOS Symposium – “Effects of the Inheritance Tax Reform”

IV. (Web)Seminars with INTES (Recurring Since 2012) and ESV

1. Planned in 2021: Professionalizing Family Assets (ESV Academy)
2. Planned in December: BDO Web Conference “Success Factors for Family Businesses in Times of Crisis”with external panel guests
3. INTES Academy: Owner Strategy Days at Lake Tegernsee (together with Karsten Schween)
4. INTES Academy: Emergency Planning for Entrepreneurs
5. INTES Academy: The International Entrepreneurial Family
6. INTES Academy: Rights and Obligations as a Shareholder
7. The Advisory Board

V. Podcasts

• 100-Minute Podcast Discussion: Family Assets in the Corona Crisis – What Now Matters
• Private-Banking-Magazin Podcast, “Das große Bild” (“The Big Picture”): “From the Control Station to theSingle Family Office”
• Equa-Stiftung: “Inheritance Tax Emergency Planning for Entrepreneurial Families”

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Speaking Engagements

• ModeratorinALPHAZIRKEL Düsseldorf
• FO andPrivate Clients Forum (Forum Institut and FAZ), yearly moderation
• Reglary speaker on seminars fürINTES Akademie for entrepreneurs

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• Member ofVdU
• FidARMember
• Member of Munich Drivers Club
• Berlin Chamber of Tax Consultants
• Hamburg Bar Association

• Founding Partner of GRÄFE Tax & Legal, 2025-Present
• Advisory board of Carl Hanser Verlag GmbH, 2024 - Present
• Founding Partner of gkn, May 2021 - December 2024
• Partner (Laywer / Tax Advisor) at BDO Munich, German Leader of Family Business and SFO Department, August 2019-March 2021
• Director / Lawyer and Tax Advisor at PwC (Hamburg, Zurich, and Munich), most recently as leader of PCS for Southern German, April 2010 - August 2019
• Associate at Flick Gocke Schaumburg, Berlin, October 2007-April 2010

• Legal Clerkship (Referendariat) at the Higher Regional Court of Hamburg, 2004–2007
• Economics Studies at FernUniversität Hagen, 2002–2005
• Magister Legum (LL.M. Taxation) at the University of Osnabrück, 2001–2002
• Research Assistant at the Chair of Capital Market Law (Prof. Dr. Dres. h.c. Theodor Baums), 1997–2001
• Law Studies (First State Examination), 2000,
• University of OsnabrückHigh School Diploma, 1996,
• Teletta Groß Gymnasium Leer