ITPJ JANUARY/FEBRUARY 2002 GERMANY Mutual Agreement Procedures and the Role of the Taxpayer Prof. Dr Berndt R. Runge 1. INTRODUCTION taxpayer will therefore increase as the scope for investiga- 1.1. Current situation tion by the tax authorities is restricted or lessened In view of this, German law extends the taxpayer's obliga Worldwide income must be taxed completely in the view tion to assist the authorities in cases r ng to cross-bor- of the tax authorities, both in Germany and in other coun- der transactions related enter- tries throughout the world. However, double taxation must prises in other co on to cooperate more be avoided. e principles There is growing potential for conflict over cross-border equ asibility and activities. Economic relations are becoming increasingly ual c t least in theory, to additional in particu- likely of audit the taxpayers and for national tax 1.2. Establishing the fac to assist the authorities capabilities if c The demands r che GmbH. division in the 2002ir