Germany and The Netherlands have agreed to immediately begin spontaneous exchange of tax information on some advance pricing agreements (APAs) and on Dutch innovation and patent box rulings, Germany’s Federal Ministry of Finance has announced.
Under the agreement, reached July 14, the tax administrations of Germany and the Netherlands will exchange information on unilateral APAs that have an impact on taxation in the other country.
Information will also be exchanged on bilateral APAs concluded with non-EU countries when either Germany or the Netherlands is not a party to the agreement but the other country is affected in terms of taxation.
With respect to bilateral APAs with EU nations, the Federal Ministry of Finance said it is pushing EU nations to wrap up deliberations by this autumn on an EU Commission proposal to introduce automatic exchange of information on rulings.
Under the EU proposal, EU tax authorities would provide information to all other EU states on APAs and other cross-border rulings issued since 2005, and, beginning January 2016, information on new rulings would be exchanged automatically every three months.
Under the new German-Netherlands agreement, information on Dutch advance tax rulings on preferential tax regimes issued for innovation and patent boxes would also be exchanged.
The agreement covers 2015 and thereafter, but the countries may also exchange information relating to earlier years, the Federal Ministry of Finance said.
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