Dieter Endres The finance ministry has issued its long-awaited decree on advance pricing agreements (APA). The ground breaking novelty for the German tax scene is that the authorities seem, for the first time, to be ready to commit themselves in advance on intentions rather than facts. An APA is to be negotiated by the Central Tax Office at the request of the German taxpayer with the competent authority of the other state under the double tax treaty. This overcomes official reticence on tax deals, but does mean that APAs will be bilateral. A multilateral effect is achievable by negotiating the same agreement with each of the relevant national authorities.
December 01 2006