Type of publication: Technical

AGN EMEA Taxation Task Force (TTF) Newsletter

A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalization of the economy and global tax efficient structures set-up by large multinational enterprises (MNEs). The Global Anti-Base Erosion (GloBE) Rules are an important component of this plan and ensure large MNEs pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. This is also known as “Pillar 2” (hereinafter also shortly referred to as “P2”) and will be relevant for strategic tax structuring of MNEs.

AGN EMEA Tax Committee News.

The requirement to create transfer pricing documentation impacts not just large corporations, but also small and medium-sized businesses (SME’s), who often lack awareness of this obligation. It’s crucial to address this issue promptly to prevent time constraints and potential penalties from tax authorities if documentation becomes necessary.

Read on for a summary of the obligations that exist in Germany and what you should be prepared for.

AGN EMEA Tax Committee News

Public Country-by-Country Reporting – To what extent do large companies contribute to public prosperity through their taxes? Public Country-by-Country Reporting (CbCR) is a regulatory requirement for corporations to disclose detailed financial and operational information on a country-by-country basis.