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On 5 June 2024 the German government published the draft bill for an Annual Tax Act for 2024. Amongst other areas of German income taxation, the bill especially includes changes and new regulations that affect the area of tax restructuring, which can be seen, at least in part, as a response by the legislature to recent judgments by the German Federal Constitu-tional Court and Federal Fiscal Court. In this article, we take a look at the proposed changes and their potential effects.

Federal Ministry of Finance allows nationals of EU or EEA member states with residence or habitual abode in Switzerland to apply for voluntary income tax filing in Germany.

On 17 July 2024 the German government adopted a growth initiative to boost Germany’s attractiveness, competitiveness and innovative strength as a place to do business. In addition to simplifying tax law, tax concessions for overtime and foreign skilled workers are intended to make Germany more attractive as a place to do business.

In this post, we let you know the details and show you what to pay attention to with practical im-plementation.

Including an increase in funding volumes and faster payout. We’ve put the most important details together below.

Two changes to the German Foreign Tax Act (Außensteuergesetz – AStG) will affect the treatment of intercompany cross-border financing transactions for tax periods from 2024. This post summarizes the new rules.

A new report from the OECD provides fixed margin ranges for limited risk distribution and commissionaire activities. The report forms an annex to the OECD Guidelines but it is currently unclear if Germany will apply the rules.

The Growth Opportunities Act entered into force at the end of March 2024. It contains many changes to tax which companies can benefit from. We give you an overview of the most important new developments and point out where you need to take action.

A recent ECJ ruling decides on the VAT treatment of services offered via an online platform. We present the focal aspects.

The defensive measures enshrined in the Tax Havens Defense Act (Steueroasen-Abwehrgesetz “StAbwG”) threaten to apply to Russia and the other jurisdictions newly added to the EU Blacklist as early as 1 January 2024.

The invasion of the Russian armed forces in the Ukraine on 24 February 2022 is having – as far as predictable at all – substantial short-term and long-term consequences on all areas of the economy. In December 2022, the Institute of Public Auditors in Germany (IDW) published a fourth update on the potential effects of the Ukraine war on the accounting of current financial statements.

On 12 July 2022, the federal Ministry of Finance (BMF) published a draft bill on DAC7. This was approved on 10 November by the Bundestag.

On 2 August 2022, the tax authorities published a circular on the application of tax deductions under 50a of the German Income Tax Act (Einkommensteuergesetz – EStG) for remuneration from software development services. The BMF circular concerns cases in which German businesses develop software using businesses that are resident abroad.

In a surprise move as part of the third relief package, the federal government decided to begin implementation of internationally agreed global minimum tax on the national level now. This once more increases the relevance for German businesses coming with the scope of Pillar Two to get themselves prepared.

Many questions still remain unanswered in regulating how global minimum tax is to be implemented. Our update on the current situation of Pillar Two and an assessment of further developments.

In May 2022, the European Commission presented a draft directive to equal out the tax treatment of equity and debt, which allows for the deduction of notional interest on equity on the one hand, and contains a further limitation on interest deduction on the other.