The German Ministry of Finance published a draft bill on 1 June 2016 to incorporate guidance on transfer pricing documentation and country-by-country (CbC) reporting into local legislation. The draft bill required multinationals with consolidated group turnover of EUR 750 million to file an annual country-by-country report (CbCR).
In addition, German taxpayers that are part of a multinational with a consolidated turnover of at least EUR 100 million in the preceding year, should prepare a Master File and Local File for Transfer Pricing and branch allocation documentation purposes. The law shall be passed by the parliament by the end of the year so that the new regulation can come into force from 2016.
