Until further notice, the BZSt, as the competent authority for APAs, will not initiate any new procedures aimed at concluding APAs with China.
Germany has temporarily suspended the initiation of new advance pricing agreements (APAs) with China, citing recent difficulties in achieving key objectives through bilateral negotiations.
In accordance with Section 89a of the German Fiscal Code (Abgabenordnung, AO), the Federal Central Tax Office (Bundeszentralamt für Steuern – BZSt) conducts APA procedures aimed at avoiding double taxation and achieving a mutual interpretation of tax treaties with the competent foreign authority.
The BZSt, in a notice, announced that these objectives could no longer be achieved in negotiations with China. Until further notice, the BZSt, as the competent authority for APAs, will not initiate any new procedures aimed at concluding APAs with China. This also applies to renewals.
Ongoing APA procedures are not affected by this measure. Efforts are being made to improve the current situation.
