OECD adopts report on Amount B
The OECD has presented its final report on Pillar One / Amount B. The determination and tax audit of international transfer prices of sales companies could be significantly simplified in future.
The OECD has presented its final report on Pillar One / Amount B. The determination and tax audit of international transfer prices of sales companies could be significantly simplified in future.
Although not explicitly provided for in the law, the Federal Fiscal Court ruled on 6 September 2023 that the exit tax arising in accordance with section 6 AStG is to be deferred permanently and interest-free in the event of an exit to Switzerland - if necessary with the granting of a security
The Federal Fiscal Court has issued its first decision on the issue of the relocation of functions between internationally affiliated companies. It is clear that the court does not follow the tax authorities on all points.
Germany was one of the first countries in the world to finalise the legislative process for implementing the global minimum taxation (Pillar Two). The law came into force shortly before the turn of the year and is to be applied for the first time in 2024.
The European Court of Justice (ECJ) provided more clarity on fines with a ruling on 5 December 2023: The prerequisite for a fine is fault on the part of the company.
The Tax Haven Defence Act has been in force for two years, but so far with a manageable number of cases affected. This is likely to change abruptly if Russia is declared a tax haven in the short term, as planned.
How shortly before the notary appointment may the seller in an M&A transaction upload documents to the virtual data room without special notice?
The reporting obligations applicable to private individuals and companies under the Foreign Trade and Payments Ordinance are often unknown, although they frequently apply to foreign relations. Failure to report can result in fines.
On 12.9.2023, the EU Commission published three papers aimed at significantly reforming the system of direct taxation for companies operating across borders within the EU.
The midsized business-oriented dhpg and six of the branch offices belonging to the RSM network until the end of September have decided to merge their companies. This will create the largest auditing and consulting company for owner-managed midsized businesses in Germany.