Germany–MNE Tax

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Europe

NGO report reveals German pharma company Qiagen’s tax avoidance through intercompany loans: SOMO→

October 2, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Europe

German finance minister “very confident” pillar one and two blueprints for digital economy will be agreed to in autumn: Reuters→

August 25, 2020

Europe

Germany won’t opt for six-month DAC6 reporting delay: Isabel Gottlieb / Bloomberg Tax→

July 7, 2020

Europe

German parliament approves VAT rate cut to 16 percent: Reuters→

June 30, 2020

Europe

German cabinet passes stimulus tax measures

June 12, 2020

Berlin tax practitioner, Ninja-Antonia Reggelin, notes today’s passage by Germany’s cabinet of law implementing the tax measures relevant to business, identifying a few changes from the German finance ministry’s earlier draft . . .

Europe

Germany proposes substantial VAT rate reduction, tax loss carryback expansion

June 10, 2020

German tax professional Ninja-Antonia Reggelin discusses a German finance ministry draft law released last week addressing tax policy measures relevant for businesses that were agreed to by German coalition parties in a stimulus package earlier this month . . .

Europe

German finance ministry clarifies transfer pricing proposal

May 11, 2020

Markus Kircher, a partner at Deloitte GmbH, Frankfurt/Germany, discusses recent German Finance Ministry clarifications to proposed modifications to the German transfer pricing rules . . . .

Digital Economy

Germany will use EU presidency to promote financial transactions tax, minimum tax, Merkel says: Reuters→

April 26, 2020

Europe

Netherlands and Germany agree on cross-border worker taxation in light of COVID-19

April 20, 2020

Jian Cheng Ku, Rhys Bane, and Mehdi el Manouzi, of DLA Piper Nederland N.V., Amsterdam, analyze a competent authority agreement executed by the Netherlands and German governments addressing the application and interpretation of Article 14 (income from employment) of the Netherlands-Germany tax treaty in light of recent measures to curb COVID-19 . . .

Austria

OECD publishes reports on cross-border tax dispute resolution Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden

April 10, 2020

The OECD on April 9 published stage 2 reports approved by the “Inclusive Framework on BEPS,” an OECD-led body of 135+ countries, that assess the cross border tax dispute resolution procedures . . .

Austria

Austria objects to German proposal to exclude from financial transaction tax derivatives and other speculative instruments making deal among 10 EU states less likely: The Associated Press / The New York Times→

February 4, 2020

Europe

Draft German tax law has big implications for transfer pricing

January 6, 2020

Oliver Treidler and Tom-Eric Kunz, of TP&C GmbH, Berlin, discuss a proposed law introduced by Germany’s Ministry of Finance on December 10 that would have a substantial impact on day-to-day transfer pricing in Germany . . .

Europe

Germany’s new R&D tax incentive enters into effect: Karen Hensley-Chelstowska / Duff & Phelps→

January 6, 2020

Europe

Germany advances new EU financial transaction tax proposal

December 16, 2019

German tax practitioner, Ninja-Antonia Reggelin, discusses the latest proposal for an EU-wide financial transactions tax, presented by German Finance Minister Olaf Scholz on December 9 . . .

Austria

Germany, France, Italy, seven others, supporting plan for EU tax on stock trades of a minimum of .2% of transaction value: Patricia Kowsmann / Wall Street Journal→

December 11, 2019

Belgium

Latest EU effort to make country-by-country reporting public fails

December 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

Americas

OECD’s digital tax plan would raise little revenue for France, Germany, US, and China, French Council of Economic Analysis concludes: Financial Times→

November 19, 2019

Europe

German finance ministry approves reporting obligation for cross-border tax: Federal Ministry of Finance→

November 12, 2019

EU finance ministers urge adoption of aviation tax

November 11, 2019

Finance ministers from 9 European nations on November 7 called on the European Commission to advance a proposal for . . .

Digital Economy

German legislation imposing VAT liability on online platforms is contrary to EU law, Commission asserts

October 15, 2019

The EU Commission on October 9 asked Germany to withdraw VAT changes . . .

Europe

Germany publishes revised tax law requiring disclosure of cross-border transactions

October 1, 2019

German tax practitioner Ninja-Antonia Reggelin notes that a draft German law, released September 27, requiring advisors or their clients to disclose information on cross-border transactions and structures to the national tax authorities differs from earlier versions . . .

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Europe

German finance minister endorses public country-by-country reporting of MNE tax information

September 17, 2019

German tax practitioner Ninja-Antonia Reggelin discusses the changing German position on public release of country-by-country reporting data . . .

Europe

Germany eyes cutting corporate rate to 25 percent: Birgit Jennen / Bloomberg→

September 3, 2019

Ten EU states considering German plan for .2% tax on purchases stock in EU headquartered companies: Reuters→

June 17, 2019

Europe

German cabinet passes R&D tax incentive

May 23, 2019

German practitioner Ninja-Antonia Reggelin notes that the German cabinet passed a bill introducing a new tax incentive for research and development (R&D) on Wednesday . . .

Asia-Pacific

G7 finance ministers agree on some features of international tax rewrite

July 18, 2019

G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. According to the ministers, the international tax and transfer pricing rules . . .

Europe

Germany must recognize other EU States’ profit and loss transfer agreements for tax consolidation, Commission says

July 30, 2019

The EU Commission on July 25 decided to send a letter of formal notice to Germany for refusing to recognize profit and loss . . .

Europe

EU court rules on deductibility of losses of sub-subsidiary, losses transferred through merger

June 24, 2019

Davide Anghileri of the University of Lausanne discusses two ECJ decisions released June 19 addressing when EU States are required by EU law to allow a parent company to deduct in Sweden final losses of a group member; one case involved losses of a sub-subsidiary located in Spain and the other of a Germany subsidiary later merged into its Swedish parent . . .

Americas

US formally asks the EU to “ditch” digital tax

October 22, 2018

Alan Rhode, co-founder of Taxmen.eu, discusses a US Senate Finance Committee letter, released last week, challenging the EU digital services tax, as well the latest positions of EU countries on the controversial proposal . . .

Europe

Germany suspends interest charge on late tax payments providing relief for MNEs

May 16, 2018

Ninja-Antonia Reggelin discusses the German Federal Fiscal Court’s May 14 announcement that it will suspend a law imposing large interest charges on unpaid taxes because the law may be unconstitutional . ..

Europe

First Look: Germany, Netherlands release joint statement on tax avoidance, minimum tax: Netherlands Ministry of Finance→

March 27, 2019

MNE Tax will publish an in-depth article about this development shortly.

Austria

Kerim Keser joins Duff & Phelps’ European transfer pricing practice

June 13, 2018

Kerim Keser is the new head of Duff & Phelps’ German, Swiss, and Austrian transfer pricing practice, the firm announced . . .

Digital Economy

Germany studying 15 percent withholding tax on foreign online advertising revenue: Reuters→

February 19, 2019

EU tax on tech firm revenue does not target US companies, Moscovici asserts

April 20, 2018

The EU’s proposed digital services tax is not aimed US tech companies; rather, the interim tax is designed to level the playing field for all businesses wherever located, Pierre Moscovici, EU Commissioner . . .

Europe

European court to hear German exit tax case as applied to Switzerland

January 16, 2018

The European Court of Justice on January 15 published a reference for a German case (C-581/17) Martin Wächtler . . .

Europe

Tax officials address joint audits, public country-by-country reporting, developing country tax incentives

May 24, 2016

Tax experts, including officials from Germany, the IMF, World Bank Group, and OECD, offered their views on joint audits for multinational corporations, public country-by-country reporting, and tax incentives offered by developing countries at a conference held . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin