Germany: Country-by-country reporting, BEPS | KPMG | BE

Germany: Country-by-country reporting, BEPS items in draft bill

Germany: Country-by-country reporting, BEPS

The Ministry of Finance (BMF) published a ministerial draft bill in June 2016 on implementation of country-by-country (CbC) reporting and other measures under the base erosion and profit shifting (BEPS) project.


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The ministerial draft bill is the first step for implementing the BEPS measures in German law. Completion of the legislative procedure is expected in the second half of 2016. Additional BEPS measures—for example, in the areas of hybrid mismatch arrangements and CFC taxation—are expected to be included in subsequent bill.

Among the provisions in the now pending legislation are measures for:

  • Implementation of the OECD recommendations regarding transfer pricing documentation (Master file, Local file, and CbC reports), for initial preparation for fiscal years beginning after 31 December 2015
  • Automatic exchange of cross-border tax rulings and advance transfer pricing arrangements between related enterprises, for advance tax rulings and advance arrangements entered into or amended since 1 January 2012
  • How to determine the arm’s length principle in tax treaty situations


Read a July 2016 report [PDF 418 KB] prepared by the KPMG member firm in Germany

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