A major reform of the international tax system finalized on 8 October 2021 at the OECD will ensure that Multinational Enterprises (MNEs) will be subject to a minimum 15% tax rate from 2023. The landmark deal will also reallocate more than USD 125 billion of profits from around 100 of the world’s largest and most profitable MNEs to countries worldwide, ensuring that these firms pay a fair share of tax wherever they operate and generate profits.
On 1 July 2021, the OECD reached broad agreement on key points for a fair taxation: 130 countries and jurisdictions have joined a new two-pillar plan to reform international taxation rules and ensure that multinational enterprises pay a fair share of tax wherever they operate.
The online courses will be available to anyone overseas who wants to gain an understanding of Japan’s international taxation regime. The charge for each course varies depending on the topics selected.
Congress on December 20, 2017 gave final approval to the House and Senate conference committee agreement on tax reform legislation that would lower business and individual tax rates, modernize US international tax rules, and provide the most significant overhaul of the US tax code in more than 30 years. President Trump signed the tax bill on 22 December 2017.
In light of global trading of multinational corporations the tax offices are in constant pursuit of stronger international tax compliance. The German Federal Finance Ministry has now issued guidelines on coordinated external tax audits with foreign tax administrations.
On 13 February 2026, the Federal Ministry of Finance (MoF) sent a comprehensive draft circular on the principles applied by the tax administration regarding the concept of a permanent establishment and the establishment of a permanent establishment in domestic and international tax law to interested associations for comment by 13 March 2026. The circular aims to systematically present the factual requirements for a permanent establishment under Section 12 of the General Tax Code (GTC) that are relevant for the application of numerous income tax regulations and to clarify the relationship to the concept of a permanent establishment under treaty law in accordance with Article 5 of the OECD Model Tax Convention. The circular takes comprehensive account of the current case law of the Supreme T ...
On August 6, 2025, the Federal Ministry of Finance (MoF) sent the draft bill for a law to adjust the Minimum Tax Act (“MTA”) and implement further measures (“MTAA – Draft”) to the associations for comment by August 11, 2025. The draft bill includes measures for the implementation of the OECD Administrative Guidance on Article 9.1 of the Global Anti-Base Erosion Model Rules from January 2025 as well as “accompanying measures" that are intended to contribute to the simplification of international tax law ("decluttering") outside the scope of the MTA.
In conclusions approved on 5 October 2021, the Council decided to remove Anguilla, Dominica and Seychelles from the EU list of non-cooperative countries and territories for tax purposes. All three had previously been placed on the “black list” because they did not meet the EU’s tax transparency criteria of being ranked as at least ‘largely compliant’ by the OECD Global Forum regarding the exchange of information on request.
In its last session of the year, the Federal Assembly (Bundesrat) gave its assent today to the Act to Implement the Amendments to the EU Mutual Assistance Directive and to Introduce Further Measures to Combat Profit Reduction and Profit Shifting
The federal government and federal states have agreed unanimously upon the criteria for a revision of the tax treatment of existing cum/cum structures. The tax authorities of the federal states could then – according to comprehensive and standardised criteria - attack cum/cum transactions, which were executed before the change in the law as at 31 December 2015.
The German Federal Parliament passed the Annual Tax Act 2022 on 2 December 2022. Among other provisions, the Act introduces (transitional) legislative changes to the taxation of payments for IP rights that are registered in a German register between foreign taxpayers.
The finance ministry has drafted a decree setting forth the administrative and other regulations to be followed by banks in fulfilment of their US FATCA obligations.
On 7 June 2017 Germany together with the representatives of over 60 countries signed the multilateral convention, which should transpose the main recommendations of the G20/OECD Project against Base Erosion and Profit Shifting (BEPS Project) into existing bilateral tax treaties.
On 14 April 2025 the Council adopted a directive (DAC9) that will extend cooperation and information exchange in the area of minimum effective corporate taxation.
The tax authorities have now published the final Ministry of Finance circular answering questions in connection with the application of the exchange of financial information and the FATCA agreement. The draft versions of the circular had previously been released and these are now in a final version.
In its sitting on 2 June 2017 the Bundesrat (the Upper House) approved the legislation which the government introduced at the end of last year following the publication of the Panama Papers.
Ground-breaking new EU rules come into effect from 1 January 2024 introducing a minimum rate of effective taxation of 15% for multinational companies active in EU Member States.
On 20 December 2016 legislation was passed introducing measures to combat base erosion and profit shifting. A part of this legislation - introduced in the new Section 138a of the General Tax Code - imposed an obligation on multinational enterprises to report annually for each tax jurisdiction in which they do business, so-called Country-by-Country (CbC) reports.
On 22 February 2017 the federal government approved a draft bill to implement both the fourth EU money laundering directive and the EU regulation on the transfer of funds as well as to reorganise the Central Financial Transactions Investigation Agency. The intention is to up-date and strengthen measures developed to prevent money laundering and the financing of terrorism.
In its sitting on 2 June 2017 the Bundesrat (the Upper House) approved the Act to Combat Harmful Tax Practices in connection with the Licensing of Rights.
