Recent Changes Made to the German APA Environment

In recent years, Germany has steadily advanced a framework for advance pricing agreement (APA) procedures. Until 2021, the Federal Central Tax Office (FCTO) conducted corresponding procedures under double tax avoidance (DTA) regulations modeled on Article 25 of the OECD Model Tax Convention, with specifics described in a Circular (October 5, 2006) issued by the German Federal Ministry of Finance. The German commitment was then issued as an advance ruling. The Circular provided details on the application requirements, procedures, and how any preliminary agreement reached was to be implemented. According to this Circular, the purpose of an APA was previously only ...