Since 1 July 2020, certain cross-border tax arrangements must be reported to the German tax authorities (DAC6 reporting obligations). After publishing the draft of a letter of interpretation in July 2020, Germany’s Federal Ministry of Finance (BMF) unveiled the final version on 29 March 2021.
In the over 70-page document, the BMF provides its interpretation of the many undefined legal concepts in the statutory provisions on DAC6 and whitelists standard cases that would generally not lead to a reporting obligation.