The Federal Ministry of Finance recently published a notice on the current issue of the Federal Central Tax Office’s newsletter, which updates the country-specific (CbC) reporting requirements due to the 2020 Annual Tax Act.

As a result of the Annual Tax Law 2020, the words “based on the consolidated financial statements” have been deleted from Section 138a, Paragraph 2, Number 1 of the Tax Code. This deletion makes it clear that in addition to the consolidated financial statements, other data sources, such as internal accounting, may be used to create the CbC report.

Consequently, all business units must be included in the CbC report. The amendments apply to all open cases. Specifically, this means that this adjustment will apply to all CbC reports that have been or will be submitted after 29 December 2020. The correction of a CbC report that has already been submitted means that the case is to be regarded as open again.