Copying and distributing are prohibited without permission of the publisher

Germany Archive

  • August 2019

    What to expect at the IFA 2019 Congress

    August 09, 2019

    International Tax Review speaks to IFA President Murray Clayson about the prospects for “radical change” on digital tax and why the London Congress will focus on BEPS Action 4 and the challenges facing investment funds.

  • July 2019

    G7 leaders push ahead with global minimum tax

    July 19, 2019

    The finance ministers of the G7 countries have agreed that a global minimum tax should be introduced to ensure companies like Facebook and Amazon pay ‘their fair share of tax’.

  • Survey results: Untangling CFC structures

    July 15, 2019

    Multinational businesses are simplifying structures to navigate the rules that target controlled foreign corporations (CFCs) and their shareholders. ITR asked those tax heads who have adopted this approach to share their business’s operational changes.

  • France and the US clash over digital service tax plans

    July 12, 2019

    The US has ramped up its opposition to France’s digital services tax (DST) by opening an investigation into it, but French senators have defiantly approved the so-called ‘GAFA’ tax anyway.

  • Market insight: People moves

    July 10, 2019

    In this month’s round-up of individual and company changes, Andersen Global expanded into the Middle East, while several tax teams in Central America grew and a number of lead partners were appointed to major firms worldwide.

  • Global minimum taxation: A matter of time

    July 10, 2019

    Minimum tax red flags have appeared in recent legislation as countries and organisations race to address perceived inequities within the international tax regime.

  • Companies measure tax departments on their ability to cut risk, not effective tax rates

    July 10, 2019

    Managing tax risk is the most important metric by which tax departments are measured, with the more traditional target of lowering the company’s effective tax rate being less important to tax heads. However, CEOs seem to know little about tax KPIs and how, or why, they are chosen.

  • Businesses disappointed with OECD’s digital tax progress

    July 10, 2019

    As G20 countries ratify the OECD’s work on taxing the digital economy, tax executives expressed their concern to International Tax Review that the body has not moved beyond proposals that they find problematic.

  • European Tax Awards 2019: The winners

    July 10, 2019

    The winners of International Tax Review’s 15th European Tax Awards have been announced.

  • Tax Advisory Survey 2019

    July 10, 2019

    Tax and trade wars among governments and the battles companies face against tax authorities through audits and inevitable disputes mean even the most super-human tax director among us needs a little help.

  • Only one way out: Simplifying CFC regimes

    July 10, 2019

    The number of countries adopting controlled foreign corporation (CFC) regimes has complicated business operations and forced them to change. Danish Mehboob talks to taxpayers who are trying to avoid getting lost in the labyrinth of multiple tax risks and unexpected audits.

  • Tax heads encourage more companies to use ICAP

    July 10, 2019

    Tax leaders from Barilla, Repsol and Shell have encouraged their contemporaries to sign up for the International Compliance Assurance Programme (ICAP), before the window to get involved closes later this month.

  • Case study: Repsol’s participation in ICAP

    July 10, 2019

    Rocío Bermúdez, tax global practices & transfer pricing senior manager at Repsol, spoke to ITR about her company’s participation in the first pilot of the International Compliance Assurance Programme.

  • The negative aspects of ICAP

    July 10, 2019

    While feedback on the International Compliance Assurance Programme (ICAP) has been overwhelmingly positive, unsurprisingly, the first pilot did encounter some teething problems.

  • OECD won’t rush ICAP expansion despite scheme’s popularity

    July 10, 2019

    The OECD’s Achim Pross says his ultimate aim is to expand the International Compliance Assurance Programme (ICAP), but companies may be disappointed to learn that it could be a relatively slow process.

  • Tax transformation: What companies need to know

    July 10, 2019

    In a wide-ranging interview, ITR speaks to Terri LaRae, partner and leader of the global operations transformation tax team at Deloitte, about the factors driving tax transformation and how tax departments can get the best out of it.

  • Germany: Relocations of functions and adjustment payments

    July 10, 2019

    Germany has been an early indicator of how the OECD’s rules on so-called ‘hard-to-value intangibles’ may look when implemented at the national level.

  • How concerned should companies be about data they send to tax authorities becoming public?

    July 10, 2019

    It’s interesting that the subject of data submitted to the tax authorities becoming public, either through a data leak or public country-by-country reporting (CbCR), is clearly still a significant concern among tax directors.

  • DAC6 fixes tax loopholes but confuses taxpayers

    July 08, 2019

    Banks are confused about how to follow the ‘vague hallmarks’ in the EU mandatory disclosure regime (DAC6).

  • June 2019

    Tax heads: DSTs are not illegal or discriminatory

    June 24, 2019

    A panel of tax experts surveyed by International Tax Review say digital services taxes (DSTs) are distortive and must be temporary – but few thought they were illegal or discriminatory.

  • ‘The hunt is on’ to find aggressive structures that work

    June 17, 2019

    While most companies are moving away from aggressive tax planning, some in-house tax directors say they are still looking for new structures to reduce their effective tax rate (ETR).

  • Tax professionals: it is time to change the global corporate tax rules

    June 14, 2019

    Tax chiefs have used International Tax Review’s survey on the taxation of the digital economy to say that international corporate tax rules are not working – but are divided on what should replace them.

  • May 2019

    OECD to consider worldwide fractional apportionment

    May 31, 2019

    The OECD’s Inclusive Framework countries have agreed to a 40-page report that outlines potential ways to tax the digital economy. The document suggests, among other measures, introducing worldwide fractional apportionment for corporate profits.

  • The future of VAT – cross-border transactions

    May 28, 2019

    The European Commission (EC) has published details of its plan to reform the EU VAT system with regard to cross-border trade. Antonio Lanotte, a European senior finance manager and professional tax advisor, gives an overview of the plans, focusing on why we need a new VAT system, what will change, when it will change and what the consequences will be.

  • Intangibles: Re-engineering substance

    May 28, 2019

    The BEPS project has had a fundamental impact on how multinational companies are structuring their intangible assets. Josh White investigates how businesses are reorganising their tax arrangements to meet their commercial needs

  • Exercising judgement as the head of tax

    May 28, 2019

    Heads of tax are called upon to make decisions continually, ranging from routine choices to the less frequent, but materially significant. Making decisions involves a combination of exercising judgement and drawing on structured processes to reduce risk writes Sandy Markwick, head of the Tax Director Network at Winmark.

  • Germany: A practical solution for hard to value intangibles

    May 28, 2019

    It is likely that many tax disputes will arise from the new definition of hard to value intangibles (HTVI) in the OECD's transfer pricing (TP) guidelines.

  • Conflicts rise over which OECD pillar should come first

    May 22, 2019

    Businesses and tax experts involved in the digital tax debate cannot agree over which of the OECD’s proposed pillars ought to be implemented first, and whether there is a real need for either.

  • Reorganisations slow amid vague indirect transfer tax regimes

    May 16, 2019

    Uncertainty over how to tax offshore indirect transfers and delay to establishing an international framework for taxing such transfers is leading to a slowdown in corporate reorganisations.

  • April 2019

    ERP systems preferred over tax engines to determine tax payments

    April 15, 2019

    Tax directors explain why they prefer ERP system customisations over tax engines to help them automatically determine their tax liabilities despite both options having their fair share of problems.

  • Companies struggle with tax planning cost of Brexit despite another delay

    April 12, 2019

    The UK and EU have announced a six-month delay to Brexit – but companies and their tax departments are facing huge financial and opportunity costs nonetheless.

  • Will anything stem the tide of unilateral VAT changes in Europe?

    April 10, 2019

    Heads of tax have expressed consternation at the continued lack of harmony in the EU’s VAT regime and the ongoing proliferation of unilateral VAT measures within the bloc.

  • GRI’s tax initiative threatens to overtake CbCR on tax transparency

    April 05, 2019

    Tax directors are backing an independent standard-setting body, the Global Reporting Initiative (GRI), to introduce a worldwide standard to tax reporting and public disclosures, but many worry that the standard will clash with country-by-country reporting (CbCR).

  • Media companies support digital taxation proposals

    April 05, 2019

    Media-related businesses are united in their desire to ‘level the playing field’ on taxing traditional and digital companies, but they do not all agree on the best way forward.

  • Tax Disputes Summit: Meet the speakers

    April 03, 2019

    Tax leaders from Acer, H&M, Swiss Re, the Portuguese Centre for Administrative Arbitration, the Finnish and Danish tax authorities, White & Case and William Fry speak to International Tax Review about trends, predictions and what is keeping them busy ahead of the ITR Tax Disputes Summit.

  • The world’s best tax transactional firms 2019

    April 03, 2019

    International Tax Review presents key trends and developments in the tax transactional market and ranks the best firms to help companies navigate the post-BEPS environment that poses challenges in restructuring and mergers and acquisitions.

  • Survey: Untangling CFC rules and regimes

    April 01, 2019

    Companies have to navigate a web of differing rules targeting controlled foreign corporations (CFCs) and their shareholders, but the process is far from easy when the distinctions in each country’s rules risk unexpected audits or an unreasonably high tax burden.

  • March 2019

    What you need to know before taking out tax insurance

    March 21, 2019

  • Stepping up: Companies get into the stride of post-BEPS tax transactions

    March 21, 2019

    After a buoyant start to 2018, M&A activity tailed off in the final quarter of the year. Despite this, for transactional tax, many large companies are restructuring as they adjust to the US Tax Cuts and Jobs Act, post-BEPS rules such as the EU Anti-Tax Avoidance Directive, and to the new reality of the digital economy.

  • Government and customers – the driving force of digitisation

    March 21, 2019

    Kim Hau, senior proposition manager for ONESOURCE Indirect Tax at Thomson Reuters, explains why corporate indirect tax teams must shift their approach from ‘surviving’ the compliance cycle to a more proactive and considered way of working.

  • Austria’s platform VAT law advances digital tax conversation

    March 21, 2019

    A package proposed by the Austrian government includes a reform to platforms’ VAT obligations, mirroring the laws in the UK and Germany. However, with the EU poised to act in 2021, Alexander Hartley asks why Austria is bothering to move in 2020.

  • France to push G7 countries for a global minimum corporate tax

    March 21, 2019

    France plans to make significant progress with members of the G7 group of countries to reach an agreement on a minimum corporate tax rate, after the OECD has presented its work on taxing the digital economy to the G20 in June.

  • MNEs accept higher tax burden is inevitable at OECD digital tax consultation

    March 14, 2019

    Corporate tax heads at the OECD digital tax consultation in Paris admitted that they would need to bow to political pressure and accept potentially painful reforms.

  • February 2019

    Companies turn to insurance to push through M&A deals

    February 15, 2019

    Companies in the private equity and real estate sectors are increasingly turning to tax-specific insurance to expedite M&A deals.

  • The OECD’s four proposals to tax the digital economy

    February 14, 2019

    The leading proposal in the OECD’s two-week consultation on four possible approaches to taxing the digital economy focuses on marketing intangibles, expanding the number of businesses that could fall under its scope.

  • Submit now for World Tax and World TP 2020

    February 11, 2019

    We are pleased to announce the official launch of World Tax and World TP 2020.

  • WTS hires Munich partner and Stuttgart director

    February 11, 2019

    WTS Global has appointed Helge Jacobs and Klaus Siler in new roles.

  • Investor pressure drives corporate tax policy development

    February 01, 2019

    Investors are giving serious consideration to their targets’ corporate tax policies before agreeing on the deal, but there are a number of companies that still have no such policy in place.

  • January 2019

    Financial institutions adapt to tax transparency

    January 28, 2019

    Tax transparency initiatives such as the CRS, AEOI and FATCA, and the upcoming mandatory disclosure rules, are having a profound impact on the operations and IT infrastructure of financial institutions (FIs) worldwide. Ronald Frey, chief product officer of the RegTech product unit within BearingPoint, discusses how these are creating trends towards data alignment and centralisation, and are changing the role of FIs and wealth managers in cross-border tax reporting.

  • The battle for resources: Making the case for tax departments

    January 28, 2019

    The rate of change in the tax regulatory environment in recent years has been rapid, arguably more so than at any other time in recent history. Heads of tax are competing with colleagues in other functions for a share of finite budgets. The challenge is to show value for money, writes Sandy Markwick, head of the Tax Director Network at Winmark.

  • Germany: Digitisation trends and use of the profit split method

    January 28, 2019

  • Not another tax department transformation

    January 28, 2019

    One of the principal subjects of discussion and analysis in tax in recent months is digitalisation. I am not only talking about the OECD, EU and unilateral proposals to address the taxation of the digital, or digitalised, economy, but also the potential of digital innovations to change business, tax administration and tax department processes.

  • EU’s majority voting proposal puts CCCTB back on the table

    January 21, 2019

    The common consolidated corporate tax base (CCCTB) and digital services tax (DST) could be introduced if the EU Commission’s proposal for qualified majority voting (QMV) succeeds.

  • PKF Frankfurt joins RSM

    January 14, 2019

    RSM GmbH merged with PKF Frankfurt on January 1 2019 to create one of the leading mid-sized tax advisory firms in Germany.

  • What the G20 should know about international cryptocurrency tax policy

    January 07, 2019

    International cryptocurrency tax policy can achieve trust if it is done correctly, writes Michael Minihan, partner at BX3 Capital.

International Correspondents