The updated decree incorporates recent taxpayer favorable jurisprudence from the federal tax court ..read more

Draft guidance provides details about the application of new TP rules included in the Growth Opportunities Act that was introduced in March 2024 ..read more

The implementation of a principal structure and the resulting change in the profit potential of a German entity does not automatically result in the transfer of a function ..read more

Final guidance includes several updates compared to the original 2023 draft version ..read more

On 5 June 2024, the German government published its plan for a growth initiative to revitalize Germany's economy. The new initiative is the result of budget negotiations among the social democratic party, liberal party, and green party, which are representing the current governing coalition, and should boost the German econcomy and provide relief for businesses from bureaucracy and levies. The long-term growth potential of the German economy and its competitiveness should be increased, and Germany should be strengthened as a business location ..read more

The new guidance has been highly anticipated since the introduction in 2021 of the legal basis for filing an advance pricing agreement request ..read more

An interest in a partnership should not be harmful for making use of an exception from the general change-in-ownership rules for trade tax purposes ..read more

With the letter dated March 11, 2024, the tax administration has published significant changes to the so-called GoBD (Principles for the Proper Management and Retention of Books, Records and Documents in Electronic Form, as well as Data Access), which came into effect on April 1, 2024. In addition to an extension of the ability of the tax auditor to estimate taxation basis in course of audits, the letter also includes changes to the manner in which audit-relevant data is made available to the tax administration. In conjunction with the discussion draft on the standardized digital interface for ..read more

Certain payments made to German resident partners in a US partnership are tax exempt even if only partially taxed in the US ..read more

Draft proposal includes technical updates and amendments without any tax reform proposals ..read more