Tighter German Anti-Treaty-Shopping Rules
Implementation of the Global Minimum Tax in Germany
On 16 August 2023, the German Federal Cabinet approved the government‘s draft for the Minimum Tax Directive Implementation Act. This makes it concrete what requirements large corporate groups in Germany will have to consider.
Global Minimum Tax: Ebner Stolz Transitional CBCR Safe Harbour Quick Check as First Assessment of the Need for Action
As of 2024, large corporate groups have to assess for the first time the extent to which a top-up tax is payable due to the requirements of the global minimum tax (Pillar II). In this context, even if all group entities are resident in jurisdictions with a nominal corporate tax rate far above the minimum tax rate of 15 %, the issue of the global minimum tax is not settled. However, temporary simplifications might be applicable. Our tool-based approach with the Ebner Stolz Transitional CbCR Safe Harbour Quick Check provides an initial assessment.
Doing Business in Germany
This guide to Doing Business in Germany is intended to provide an initial overview of the political, economic, legal and tax environment for investing in this country, so as to facilitate potential investors’ decision-making about a German business commitment.
The Global Minimum Tax - A Challenge for Groups of Enterprises
Long thought impossible, a breakthrough was achieved in 2021 when almost 140 countries agreed to introduce a global minimum tax. The basic principles developed by the OECD and the G20 are now to be quickly implemented into EU law and applied consistently in the EU. The new rules could become a big challenge for a large number of group enterprises.
Specifications of the german tax authorities regarding DAC6
Since 1 July 2020, certain cross-border tax arrangements must be reported to the German tax authorities (DAC6 reporting obligations). After publishing the draft of a letter of interpretation in July 2020, Germany’s Federal Ministry of Finance (BMF) unveiled the final version on 29 March 2021.