After almost a decade of intense developments and numerous new regulations, ordinances and administrative principles on transfer pricing in Germany (including the widely commented on introduction of the rules on transfers of business functions), 2011 has been a quiet year. This should not, however, lead to the conclusion that the German Ministry of Finance has shifted its focus away from transfer pricing matters or is taking time to reflect on the comprehensive rules introduced so far before deciding what steps to take next. Lorenz Bernhardt and Michael Jakob of PwC run-through the anticipated tax developments in German transfer pricing.
The Foreign Account Tax Compliance Act (FATCA) has only very few key provisions but, even before its material application, it belongs to the most complicated pieces of modern US tax law. Achim Obermann and Oliver von Schweinitz of PwC explain the complexities involved for US and non-US financial institutions.
The implementing regulations to the EC VAT Directive have resulted in an interpretation issue with VAT fixed establishments. Björn Ahrens and Michael Häring of PwC explain why the German tax authorities’ interpretation of the term is at least misleading and what the practical consequences of such interpretations might be.
Despite the European debt crisis, Germany’s fiscal revenue in 2011 will be much higher than estimated. However, it remains uncertain whether the discussion about an abolition of the solidarity surcharge and reduction of income tax rates will survive the Christmas holidays. But it proves true that German tax law always has interesting news to report even if there no major tax reforms. Stefan Ditsch, Barbara Zuber and Alexander Just of PwC discuss Germany’s tax developments.