Joint Audits – Any agreement reached between the tax administrations is not how taxpayers are eventually being taxed

Driven by the OECD’s Base Erosion and Profit Shifting (“BEPS”) initiative, there is a trend towards cross-border administrative cooperation in the context of international tax law. This trend manifests itself in concrete measures such as the International Compliance Assurance Programme (“ICAP”) and joint tax audits (“Joint Audits”). The latter express the desire to achieve legal …

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No surprises: Ministry of Finance clarifies that it never wanted to introduce the price-setting approach into German transfer pricing rules

On 10 December 2019, the German Federal Ministry of Finance published a draft bill of the so-called ATAD Implementation Act (“ATAD-UmsG“) by which the second European Anti Tax Avoidance Directive (“ATAD II”) should be implemented into German national law. This draft not only contained amended provisions related to the already existing German CFC rules and …

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