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German Ministry of Finance regulations comment on Advance Mutual Agreements, including Advance Pricing Agreements

30 July 2024

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Tax Alerts, National/Federal Taxation, T...

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Germany

The German Ministry of Finance has issued an updated administrative regulation dealing with bilateral and multilateral Advance Mutual Agreements.The updated regulation only partially clarifies the existing practical application issues, however. Executive summaryOn 26 June 2024, the German Ministry of Finance (MoF) issued an updated administrative regulation to the German Fiscal Code (AEAO). The update represents the first time that the MoF has formally commented on the new provision for bilateral and multilateral Advance Mutual Agreements (Sec. 89a German Fiscal Code).BackgroundIn 2021, the German legislature introduced a new legal basis in Germany for bilateral and multilateral Advance Mutual Agreements (Advance Pricing Agreements...