Germany gazettes amendment regulation for exchange of CbC reports
On 27 February 2023, the German official Gazette issued a regulation amending the list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the exchange of country-by-country (CbC) reports. The law came into
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Germany publishes list of Jurisdictions for Automatic Exchange of Information
On 23 February 2023, the German Ministry of Finance has released an updated list of jurisdictions that will receive financial account information automatically for tax purposes starting on 30 September 2023. For 2023, six new countries have been
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Germany: Lower house of parliament adopts CbC exchange agreement with USA
On 9 February 2023, the German lower house of parliament (Bundestag) has approved a law to ratify the pending agreement with the USA on the exchange of CbC reports. The agreement was signed on 14 August 2020. The agreement will enter into force when
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Germany passed law for implementation of DAC7
On 16 December 2022, Germany passed the DAC7 to modernize tax procedural law. The new law amended Section 90 of the General Tax Code (GTC) and tightened the rules on transfer pricing documentation by allowing tax authorities to request transfer
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Germany introduces windfall profits tax for power sector
On 23 December 2022, Germany published the Law in the official gazette to introduce an electricity price break for purpose of change other energy law provisions. It provides for several electricity-related relief measures and the introduction of a
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Germany updates the list of jurisdictions under BEPS MLI
On 14 December 2022, Germany published a notice in the Official Gazette regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, Germany added South Africa to the
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Germany publishes a draft bill updating list of participating jurisdictions under MCAA-CbC
On 23 November 2023, the German Ministry of Finance published a draft bill providing an updated list of jurisdictions participating under the Multilateral Competent Authority Agreement (MCAA) on the exchange of CbC reports. Accordingly, Germany will
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Germany: Federal Cabinet approves CbC reports exchange agreement with US
On 4 November 2022, the German Upper House of Parliament (Bundesrat) approves bill No. 567/22 for consideration to ratify the competent authority agreement (CAA) on the exchange of country-by-country (CbC) reports with the US. The competent
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Germany: CJEU has issued a decision on sanctions for non-compliance with TP documentation requirements
On 13 October 2022, the Court of Justice of the European Union (CJEU) ruled in case: C-431/21 on sanctions for non-compliance with transfer pricing (TP) documentation requirements. Under German law, there is a rebuttable presumption that the
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Germany: Government publishes a draft bill for public CbC reporting
On 30 September 2022, the German Federal Ministry of Justice published draft legislation for the implementation of EU public country-by-country (CbC) reporting Directive 2021/2101 as regards the disclosure of income tax information by certain
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Germany enacts the bill on the interest rate for late payment
On 21 July 2022, The Ministry of Finance published the bill providing for a reduced rate for late interest payments on excess payments and refunds of tax in the Official Gazette. The bill had been previously approved by the lower house of the
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Germany: MoF publishes a draft decree-law regarding the transfer of functions
On 5 July 2022, the German Federal Ministry of Finance published a draft decree-law regarding the transfer of functions. The aim of the draft decree-law is to adapt and restructure the existing regulations on the arm's length principle with the
See MoreIMF Report Recommends Policy Changes for Germany
On 23 May 2022 the IMF published a report following discussions with Germany under Article IV of the IMF’s articles of agreement. Germany’s economic recovery was gathering strength before the Ukraine war began, but the war has impacted the
See MoreGermany publishes draft law on the interest rate for late payment
On 23 February 2022, the Treasury Department published a bill that would provide a reduced rate of interest on overpayments and tax refunds. The draft bill provides for reduced default interest of 0.15% per month (1.8% per year) on overpayments
See MoreGermany proposes further extensions of several fiscal measures for the COVID-19
On 3 February 2022, the German Ministry of Finance has introduced a bill that provides further measures to support taxpayers during the COVID-19 pandemic. The draft bill primarily provides for the retention of transitional measures that have
See MoreGermany publishes court decisions concerning the intercompany loans
On 4 November 2021, The German Ministry of Finance (MoF) published Tax Court Decision No. IR 32/17of 9 June 2021, on the taxation of corporate income based on unsecured loans to foreign related companies. In that case, a domestic company granted
See MoreGermany publishes court ruling on the arm’s-length interest rate on intercompany loans
On 21 October 2021, the German Ministry of Finance released Tax Court Decision No. IR 4/17(dated 18 May 2021), regarding the calculation of an arm's-length interest rate on intercompany loans. Under the ruling, the interest rate should be based
See MoreGermany publishes Guidance on MAP and arbitration procedures
On 27 August 2021, the Federal Ministry of Finance published guidance on mutual agreement (MAP) and arbitration procedures. The guide explains how to initiate procedures, how to carry out procedures, how to execute agreements, etc. The guidance
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