Germany: Updated general administrative regulation on tax audits; other tax developments
Other tax developments include revised guidance on minimum term of profit and loss pooling agreement and partnerships as controlling entities
September 25, 2026
The “General Administrative Regulation for Tax Audits” was published in the Federal Tax Gazette on September 9, 2026, and became effective on September 10, 2026.
The updated regulation, which replaces the previous regulations of March 15, 2000, implements amendments under the Act on the Transposition of DAC7 and the Modernization of the Tax Procedure Law of December 20, 2022, aimed at speeding up tax audits.
Other recent tax developments in Germany include:
- Federal Tax Court (IV R 36/23): Prohibition on deduction under Section 4i Income Tax Act applies when tax relief arises within framework of Dutch group taxation.
- Federal Tax Court (I R 57/23): Article 9(1) of Germany-Cyprus income tax treaty generally precludes application of purely domestic formal arm’s length requirements in context of hidden profit distribution.
- Lower Tax Court of Cologne (6 K 2020/22 and 6 K 33/22): Taxpayer entitled to interest under EU law on refund of withholding tax on dividends when processing period was excessively long.
- Federal Ministry of Finance: Revised guidance for corporate tax groups on minimum term of profit and loss pooling agreement and partnerships as controlling entities.
Read an October 2026 report prepared by the KPMG member firm in Germany