Bundeszentralamt für Steuern

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Tax Rulings

Tax rulings are preliminary tax decisions in the international context that have a cross-border effect.

German law states that "preliminary tax decisions" are binding rulings within the meaning of Section 89 (2) of the Abgabenordnung (AO – German Fiscal Code), binding commitments according to Section 204 AO and advance transfer pricing agreements as other administrative acts. Countries that are affected by the cross-border effect receive information on the existence and content of a tax ruling under certain legal circumstances.

This information is forwarded by the BZSt to the domestic and foreign tax authorities.

Leaflet

Leaflet

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Leaflet on the mandatory automatic and spontaneous exchange of binding rulings, binding commitments and advance transfer pricing agreements in conjunction with cross-border circumstances

Annex 1

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Annex 1 to the leaflet (Form for the Spontaneous Exchange of Information on Rulings according to BEPS Action 5)

Annex 2

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Annex 2 to the leaflet (OECD Publication: "More Effective Countering of Harmful Tax Practices in Consideration of Transparency and Substance, Action 5 – 2015 Final Report")

Annex 3

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Annex 3 to the leaflet (List of OECD, IF and G20 countries)



Annex 4

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Annex 4 to the leaflet (List of selected legal bases for the spontaneous exchange of information in relation to the OECD, IF and G20 countries)

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