Neue Regeln zur Aufteilung der Ertragsteuerbefugnis zwischen den Staaten

Taxpayers and primarily international enterprises are blamed for base erosion and profit shifting (BEPS). However, inconsistent rules in national and international tax law for splitting the worldwide market income are the main reason, actually, for BEPS. Adapted rules allow the worldwide market income to be taxed once in the source state and exempted in all other states: The right to taxation follows the market income sources. Cross-border profits, as is the case nowadays, are split by arm's length pricing.