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.
The ministerial draft bill is the first step for implementing the BEPS measures into German law. Additional BEPS measures—for example, in the areas of hybrid mismatch arrangements and CFC taxation—are expected to be included in subsequent bill. Completion of the legislative procedure is expected in the second half of 2016.
In addition to the BEPS-related proposals, the draft bill includes measures concerning:
Among the provisions in the now pending legislation are measures for:
Read a July 2016 report [PDF 418 KB] prepared by the KPMG member firm in Germany: German Tax Monthly (July 2016)
Other topics discussed in this KPMG report concern legislation on the reform of investment taxation; court decisions about the thin capitalization rule in upstream loans, and about the taxation of “special partner” business income under the income tax treaty with Spain; and guidance from the tax authorities about the treatment of losses in the context of imputed income.
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