Germany Issues Reporting Guidance for Transparent Partnerships

Germany published guidance on country-by-country reporting for transparent partnerships and the extent to which they can benefit from a temporary safe harbor under global minimum tax rules.

The guidance, issued Thursday, takes the form of a so-called BMF letter—a decree on the interpretation and application of federal tax laws by the tax administration. A domestic or foreign partnership is transparent if its income is only taxed at the level of individual partners.

The country-by-country reporting safe harbor is designed to temporarily simplify jurisdictional revenue and income reporting under the global minimum tax, which seeks to levy ...