Nowadays, successful enterprises - be they big multinationals or small specialists - have a strong presence in many countries. Though good for the business, this results in a plethora of tax issues. In particular, enterprises of this kind find themselves confronted with tax audits not only in Germany, but also in other countries. In times of financial crisis and discussion of BEPS, other countries involved try to obtain a bigger part of the profits from such enterprises, too, whilst the German tax authorities try to keep the profit taxable in Germany. This results in tough tax audits and increasingly in double taxation because the current mutual agreement procedures often cannot cope with the high number of disputed audit findings. Therefore, some tax authorities are testing new ways of avoiding double taxation such as parallel or joint audits.
To give you a practice-oriented overview of current issues and challenges in tax audits in Germany and other major jurisdictions in Europe, we have invited Prof. Johann-Paul Ott, head of central tax office for group auditing and partners of some of our best-friend law firms from continental Europe.
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