The Germany Federal Ministry of Finance (MoF) on 11 July 2017 issued guidance on the Country-by-Country (CbC) reporting requirements in line with BEPS Action 13 and the EU Administrative Assistance Directive as amended. If certain requirements are met by a taxpayer, CbC reports must be prepared for the first time for financial years starting on 31 December 2015.
Further, the MoF on 19 July 2017 has published a revised Decree on the type, content and scope of Transfer Pricing Documentation Regulations. The Decree provides additional guidance on the documentation measures as a result of the Act that implemented the three-tiered approach of the transfer pricing documentation requirement at the end of 2016, as recommended by the OECD under BEPS Action 13. Accordingly, the reviewed transfer pricing documentation regulations have immediate effect and are applicable for the first time for financial years starting on 31 December 2016.
