BEPS Germany Profile

July 2016


1) Has Germany implemented any BEPS recommendations? If so, which Action Items? 
Germany has not implemented any BEPS recommendations.
2) What is Germany’s expected timeline for implementing country-by-country reporting? 

Country-by-country reporting has not yet been implemented.  An exact timeline for implementation is not yet available.  It is assumed that the first country-by-country report must be provided in 2018 for the FY 2017.
3) What measures are multinationals in Germany taking to prepare for country-by-country reporting?  
Although country-by-country reporting has not yet been implemented, multinationals often do a country-by-country reporting trial run to be aware of tax risks, and to take measures to reduce those risks.
4) Are Germany’s taxing authorities taking any measures to prepare for any changes brought about by BEPS (e.g., changes in staffing, increases in budgets)? 

The German taxing authorities intend to increase competent authority staff, as cases of double taxation are expected to increase.  Detailed information on proposed measures is not available, however.
5) How will country-by-country reporting affect how you provide services to your clients? 

Most of our clients do not exceed the threshold of annual consolidated group revenue of €750 million. Nevertheless, tax risk management becomes critical when structuring clients’ business operations and reviewing existing transfer pricing structures.