Germany: Update on CCCTB, CbC reporting, court cases | KPMG | GLOBAL
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Germany: Update on CCCTB, CbC reporting, court cases

Germany: Update on CCCTB, CbC reporting, court cases

The KPMG member firm in Germany has prepared a report that discusses the following developments:


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  • EC’s proposal for major corporate tax reform, including the creation of a “common consolidated corporate tax base” (CCCTB) and amendments to the anti-tax avoidance directive regarding hybrid mismatches
  • A draft law published by the Ministry of Finance (BMF) to address tax avoidance, including a proposal for transparency regarding third-country companies
  • Procedures for ratification of the multilateral competent authority agreement (MCAA) on the exchange of country-by-country (CbC) reports
  • A federal tax court (BHF) decision about the definition “permanent establishment,” as used in German trade tax law, is defined by reference to domestic law, not by reference to an income tax treaty
  • Guidance issued by the BMF concerning the beneficial ownership of securities in the context of securities transactions 


Read a December 2016 report [PDF 351 KB] prepared by the KPMG member firm in Germany: German Tax Monthly

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