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From the latest tax updates to useful tips - our publications are designed to help you manage your tax affairs efficiently and stay well informed at all times. We would like to support you with our specialist knowledge and expertise. Please do not hesitate to contact us if you have any questions or concerns - we will be glad to help you.
On the 17th of October 2024 the German Ministry of Finance published the official form for reporting the group head of a German minimum tax group for the 2024 tax assessment period.
On August 14, 2024, the German Ministry of Finance (BMF) introduced a draft to amend the transfer pricing guidelines issued on June 6, 2023. This draft focuses on new regulations concerning financing relationships, following the revision of Section 1 of the German Foreign Tax Act (AStG) and the introduction of Sec. 1 para. 3 lit d and para. 3 lit. e AStG as part of the Growth Opportunities Act. These changes significantly impact companies subject to taxation in Germany that engage in cross-border financing relationships.
In the business-to-business area elec-tronic invoicing (e-invoice) is to be mandatory as of 2025. The legal basis for this new duty was made by the Growth Opportunities Act (Wachstumschancengesetz).
As an accounting and tax advisory firm operating throughout Germany, we offer excellent services to our medium-sized clients operating domestically and internationally.
Almost every company today has foreign relationships. While the free movement of capital gives companies more and more opportunities to structure their taxes, the collection of taxes poses a major challenge for countries. The disclosure of income tax information through pCbCR is intended to counteract this tax avoidance and create more transparency.
The draft bill for the Growth Opportunities Act originally provided for the introduction of an interest rate cap to limit the amount of interest deducted by a company. However, this was removed from the law. Instead, special regulations have been introduced in Section 1 (3d) and (3e) AStG, which specify the arm's length comparison for financing relationships.
As part of the Business Europe Framework for Income Taxation (“BEFIT”) package, published on September 12th, 2023, a proposal for issuing a European Directive, aimed at harmonising the EU regulatory framework on transfer pricing (“TP Directive”), was issued by the European Commission.
Transfer Pricing - Legal requirements for international supply and service relationships between related group entities.
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