About the author

**Paul Liese**

hsp Software

Paul Liese is the managing director of hsp Handels-Software-Partner GmbH in Hamburg. For many years, he has been involved in the **Software and IT specialist** with the topics relating to electronic invoicing. These include, in particular, procedural documentation, Tax CMS, transfer pricing and the internal control system. Together with his team, Paul Liese is working on the **Elimination of all media breaks** in accounting.

[Get in touch](../../en/order-a-demo/index.md)

[Go to LinkedIn profile](https://www.linkedin.com/in/paul-liese)

## OECD meeting in Paris: What the Pillar 2 and AI declarations mean for businesses

### What you can expect from this article

The plenary meeting of the OECD/G20 Inclusive Framework on BEPS took place in Paris from 28 to 30 October 2026. Among other things, the participating countries discussed simpler rules for the global minimum tax \(Pillar 2\) and the potential applications of AI in tax administration. But what do the statements from the meeting mean for businesses?

### Check now: Are you affected by the ‘side-by-side’ issue?

With the so-called ‘side-by-side’ package, the OECD aims to establish a framework between Pillar 2 and national minimum tax systems, in particular the US GILTI and CAMT schemes. Under this package, companies headquartered in jurisdictions with a recognised, equivalent minimum tax system are to be fully protected from foreign catch-up tax assessments. In addition, the temporary CbCR safe harbour has been extended by one year, and a permanent simplification of the calculation of the effective tax rate \(ETR\) has been discussed.

**For companies, this means checking whether the ‘side-by-side’ approach and, where applicable, the simplifications actually apply to their group of companies, the country in question and the financial year. It is also necessary to clarify which tax returns and declarations are still required. The tax department, the accounts department and the local subsidiaries should work together to determine who is responsible for providing and verifying which information.**

### Can the CbCR figures provided be explained?

With Country-by-Country Reporting \(CbCR\), more than 120 countries and tax jurisdictions have introduced country-by-country reports for corporate groups. Tax authorities use these reports to make an initial assessment of where tax risks might lie in transactions between group companies. However, even when the data is correct, noticeable discrepancies may appear in a report.

**Our recommendation: As a first step, companies should check whether the information relating to their consolidated figures is consistent with the records of internal transactions. Furthermore, companies should be able to provide a clear explanation for every figure. This is the only way to justify any noticeable discrepancies to the authorities. After all, a discrepancy is not automatically an error.**

### What can businesses expect when tax authorities turn to AI?

The OECD meeting, held as part of the „Tax Administration 3.0“ \(TA3.0\) project, also addressed the use of artificial intelligence \(AI\) in tax administration. This is driven by the expected volume of data resulting from future submissions, such as Pillar 2 reports. AI is to be used to automatically identify patterns of cross-border tax evasion and abusive tax planning.

**For businesses, this means that in future it will be virtually impossible to get away with inaccuracies or tricks. You should therefore keep a very precise record of where your tax data comes from, how the figures were calculated and who checked them. Document any discrepancies and the reasons for them. This will enable you to provide the correct answer to any queries from the tax authorities. Don’t wait until the tax authorities are sifting through your reports using the full power of AI – by then, it will be too late.**

### Conclusion: Keep reviewing, stay on top of developments, and identify added value

Even though we have been dealing with country-by-country reporting and global minimum taxation for years now, we must recognise that these issues are still in their infancy. Consequently, companies must continually adapt to new developments and changes. It’s no longer a case of simply collecting the data, submitting the report and ticking it off the list – those days are over once and for all.

For businesses, this means keeping up to date with the latest developments. We are doing our best to play our part in this. But beyond that, the new obligations also mean that companies are bringing together a great deal of valuable data, much of it for the first time. And data means knowledge that can be used to scrutinise and further optimise processes, particularly at an international level.

## More on country-by-country reporting

[### How to prepare country-by-country reports efficiently](../../en/cbcr-country-by-country-reporting/index.md)

Find out what makes good country-by-country reporting software.

[Read now](../../en/cbcr-country-by-country-reporting/index.md)

[### This Pillar 2 enquiry was initially perplexing, but then proved convincing](../../en/this-pillar-2-enquiry-initially-confused-me-but-then-won-me-over/index.md)

Paul Liese, Managing Director of hsp, was initially puzzled by an enquiry about Pillar 2. But then it all made sense.

[Read now](../../en/this-pillar-2-enquiry-initially-confused-me-but-then-won-me-over/index.md)

[### Country-by-country reporting without any gaps in coverage](../../en/country-by-country-reporting-cbcr/index.md)

What should a complete country-by-country report include? And how do I find the right software to produce it?

[Read now](../../en/country-by-country-reporting-cbcr/index.md)

FAQ – Frequently Asked Questions

Frequently Asked Questions about DSFinV-K 3.0

#### What does DSFinV-K 3.0 mean?(0cb7d515b15b204b8)

The DSFinV-K 3.0 is a new version of the tax authorities’ digital interface for point-of-sale systems. It relates to the standardised provision of certain electronic point-of-sale data for tax audits.

#### When do the new administrative regulations come into force?(c9dc50f7782cc850b)

The revised version of the AEAO relating to Section 146a of the AO will, in principle, apply from 1 January 2029. In the event of permitted early application of the DSFinV-K 3.0: the new application circular is also to be applied earlier.

#### Do businesses have to upgrade their till systems straight away?(d6fa0ef5dda384cdc)

No. The letter from the Federal Ministry of Finance dated 26 October 2026 does not impose a general obligation to switch over immediately.

#### Does the procedural documentation need to be updated?(2b368b48eda9c407d)

An adjustment may be necessary if the changeover results in changes to relevant technical or organisational processes. The decisive factor is whether the existing documentation continues to accurately describe the actual procedures.

#### Is the DSFinV-K the same as the health insurance fund notification?(6150b321f2361e4e3)

No. The DSFinV-K relates to the structured provision of POS data. The POS report pursuant to Section 146a\(4\) of the German Fiscal Code \(AO\) is a separate electronic reporting procedure.

If you have any further questions, please do not hesitate to get in touch. We look forward to hearing from you.

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