Knowledge Base Help Center
< All Topics
Print

German Transfer Pricing Regime

German Transfer Pricing Regime

Germany operates one of the most sophisticated and stringent transfer pricing regimes in Europe, combining comprehensive legislative frameworks with detailed administrative guidance that closely aligns with OECD principles 1. The German transfer pricing landscape has undergone significant transformation in recent years, culminating in substantial regulatory changes that took effect on January 1, 2025, fundamentally altering compliance obligations for multinational enterprises operating within German jurisdiction 2.

The German approach to transfer pricing enforcement reflects a commitment to preventing base erosion and profit shifting while ensuring that related-party transactions reflect arm’s length conditions 3. This comprehensive regulatory framework encompasses detailed documentation requirements, strict submission deadlines, enhanced penalty structures, and sophisticated dispute resolution mechanisms designed to provide both certainty and compliance assurance for taxpayers engaged in cross-border intercompany transactions 4.

Legal Framework and Core Legislation

Primary Legislative Foundation

The German transfer pricing regime derives its authority from several key legislative instruments, with Section 1 of the External Tax Relations Act (Außensteuergesetz, AStG) serving as the cornerstone provision establishing the arm’s length principle 5. This fundamental requirement mandates that all cross-border transactions between related parties must be conducted under conditions that would have been agreed upon between independent enterprises in comparable circumstances 6.

Section 8(3) of the Corporation Tax Act (Körperschaftsteuergesetz) provides additional substantive rules governing constructive dividend distributions, while Section 4(1) of the Income Tax Act addresses hidden capital contributions 7. The recent amendments introduced through the Growth Opportunities Act (Wachstumschancengesetz) have added Sections 1(3d) and 1(3e) to the AStG, establishing specific rules for cross-border intercompany financing relationships and financing services 8.

Administrative Guidance and Circulars

The Federal Ministry of Finance (Bundesministerium der Finanzen, BMF) issues comprehensive administrative principles that interpret and implement transfer pricing legislation 9. The most recent guidance, designated as Administrative Principles Transfer Pricing 2024 (VWG VP 2024), was published on December 12, 2024, replacing the previous 2023 version and incorporating significant updates related to intercompany financing and the OECD’s Amount B approach 10.

These administrative principles explicitly incorporate the OECD Transfer Pricing Guidelines as Annex 1, making them binding on German tax authorities and providing taxpayers with detailed guidance on implementation and interpretation 11. The German approach ensures consistency with international standards while addressing specific domestic tax considerations and compliance requirements 12.

Timeline of German Transfer Pricing Regulatory Changes (2020-2025)

Procedural Framework

Section 90 of the General Tax Code (Abgabenordnung, AO) establishes the procedural requirements for transfer pricing documentation, including the preparation, maintenance, and submission of required records 13. The Ordinance on the Documentation of Profit Allocations (Gewinnabgrenzungsaufzeichnungsverordnung, GAufzV) provides detailed specifications regarding the content and format of transfer pricing documentation 14.

Additional ordinances address specific aspects of transfer pricing compliance, including the Business Function Relocation Ordinance (Funktionsverlagerungsverordnung) and the Permanent Establishment Profit Allocation Ordinance (Betriebsstättengewinnaufteilungsverordnung) 15.

Scope of Application and Related Party Definition

Entities Subject to Transfer Pricing Rules

German transfer pricing regulations apply comprehensively to all German taxpayers engaged in cross-border transactions with related parties, including German branches of foreign companies 16. The scope encompasses domestic corporations, partnerships, sole proprietorships, and permanent establishments of foreign entities that conduct business operations within German territory 17.

Permanent establishments are subject to specific transfer pricing rules based on the Authorised OECD Approach, with important particularities reflecting German domestic law requirements 18. The application extends to all business transactions between associated enterprises, regardless of the specific legal structure or organizational form of the entities involved 19.

Related Party Criteria

Section 1(2) of the External Tax Relations Act provides a comprehensive definition of related parties that encompasses both direct and indirect relationships 20. Enterprises are considered related when one party holds, directly or indirectly, at least 25% of the subscribed capital, membership rights, participation rights, voting rights, or company assets of another party 21.

The definition also includes situations where one party is entitled to at least 25% of the profits or liquidation proceeds, or where one entity can exercise controlling influence over another, either directly or indirectly 22. Additionally, enterprises are deemed related when a third person has a substantial interest in both entities, ensuring comprehensive coverage of potential related-party arrangements 23.

Documentation Requirements and Thresholds

Three-Tiered Documentation Framework

Germany has implemented the OECD’s three-tiered approach to transfer pricing documentation, consisting of the Master File, Local File, and Country-by-Country Reporting 24. Each component serves distinct purposes and is subject to specific threshold requirements and submission obligations 25.

Master File Requirements

German entities must prepare a Master File when their total revenues exceed EUR 100 million in the preceding fiscal year and they form part of a multinational group 26. The Master File must include comprehensive information regarding the organizational structure of the multinational group, the group’s global business operations, the overall strategy for utilizing intangible assets within the value chain, and a general description of group financing arrangements 27.

Local File Thresholds and Content

Local File preparation becomes mandatory when specific transaction volume thresholds are exceeded 28. For delivery of goods or commodities to related parties, the threshold is EUR 6 million in annual remuneration, while for other transactions, particularly services, the threshold is EUR 600,000 in annual remuneration 29.

The Local File must contain detailed descriptions of business relationships with affiliates, comprehensive function and risk analyses including value chain analysis, descriptions of the transfer pricing methods employed and their application, transfer pricing analyses based on comparable data often derived from database research, and information regarding the timing of transfer price determination 30.

Transaction Matrix 

The most significant procedural change introduced in 2025 is the mandatory Transaction Matrix, required under Section 90(3) sentence 2 no. 1 AO 31. This structured, tabular overview must provide tax authorities with comprehensive details on cross-border business transactions with related parties and permanent establishments 32.

The Transaction Matrix must include the type and nature of transactions, identification of all parties involved including recipients and providers, transaction volumes and remuneration details, contractual basis for each transaction, transfer pricing method applied, relevant tax jurisdictions, and indications whether transactions are subject to non-standard taxation in relevant jurisdictions 33. The Federal Ministry of Finance published detailed guidance on April 2, 2025, clarifying the scope and format requirements for Transaction Matrix preparation 34.

Extraordinary Business Transactions

German law requires special documentation for extraordinary business transactions (EBTs), which represent transactions that deviate significantly from the normal course of business and often result in substantial changes in income 35. Examples include the conclusion and modification of long-term agreements significantly affecting taxpayer income, asset transfers as part of business restructuring measures, transfer and provision of assets in connection with significant changes in functions and risks, and business restructuring activities involving function transfers 36.

EBT documentation requires proactive and contemporaneous preparation within six months following the fiscal year in which the transaction occurs 37. The 2025 regulatory changes have intensified these requirements by mandating automatic submission upon receipt of tax audit notifications 38.

Submission Deadlines and Enforcement Mechanisms

30-Day Deadline

Beginning January 1, 2025, Germany implemented a dramatically shortened submission deadline of 30 days for transfer pricing documentation, representing a 50% reduction from the previous 60-day requirement 39. This deadline applies to Local Files including Transaction Matrix, Master Files, and extraordinary transfer pricing documentation 40.

The 30-day countdown begins automatically upon receipt of a tax audit notification, without requiring a specific request from tax authorities 41. Importantly, this deadline applies retroactively to audits covering fiscal years prior to 2025, provided the audit order is issued after December 31, 2024 42.

Expanded Authority for Documentation Requests

German tax authorities now possess enhanced authority to request transfer pricing documentation at any time, not solely during formal tax audits 43. This authority extends to annual corporate income tax assessments and Advance Pricing Agreement application processes 44. The expanded scope ensures that German companies engaged in cross-border intercompany transactions must maintain audit-ready documentation throughout the year 45.

Penalty Structure and Consequences

The German penalty framework for transfer pricing non-compliance has been significantly strengthened 46. Failure to submit the Transaction Matrix results in an automatic penalty surcharge of EUR 5,000, as specified in Section 162(4) sentence 3 AO 47.

More substantial penalties apply for inadequate or late documentation submissions, with surcharges ranging from 5% to 10% of estimated taxable income for missing or unusable documentation 48. Late submissions face daily fines, creating significant financial incentives for timely compliance 49. When documentation is deemed insufficient, German tax authorities are authorized to make income adjustments based on estimations, potentially resulting in substantial additional tax liabilities 50.

Transfer Pricing Methods and Analytical Framework

OECD-Aligned Methodological Approach

German transfer pricing analysis follows the five standard OECD transfer pricing methods: Comparable Uncontrolled Price (CUP), Resale Price Method, Cost Plus Method, Transactional Net Margin Method (TNMM), and Profit Split Method 51. The German Federal Tax Court has demonstrated a preference for applying the CUP method when determining intra-group interest rates, even when comparables are less than ideal 52.

DEMPE Framework Implementation

Germany has implemented the OECD’s DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) framework for analyzing intangible property transactions 53. The German administrative principles state that income allocation from intangible assets should be based on assumed functions and risks and measures for managing them, rather than depending solely on legal ownership or holding rights 54.

German tax authorities proactively apply the DEMPE framework in inbound contexts where returns allocated to local distribution or manufacturing entities appear relatively low 55. This approach enables authorities to challenge arrangements where German entities performing DEMPE functions receive inadequate recognition in their allocated returns 56.

Risk Control and Function Analysis

The control of risk framework represents a key element of German function and risk analysis 57. German tax authorities regularly utilize this guidance to challenge transfer pricing arrangements resulting in German entities being allocated losses 58. When loss realization results from risk materialization, authorities may argue that risks controlled outside Germany should result in loss allocation to non-resident entities that control such risks 59.

Benchmarking and Comparability Analysis

German transfer pricing compliance requires robust benchmarking studies that identify transactions between unrelated third parties comparable to controlled transactions under review 60. These studies typically utilize independent external databases providing transaction data within similar industries and regions 61.

Inadequate benchmarking studies expose taxpayers to significant risks, as German tax authorities possess authority to adjust taxable income under Section 162 AO when intercompany transactions fail to reflect arm’s length pricing 62. Insufficient documentation can result in penalties ranging from EUR 5,000 to EUR 1 million 63.

Recent Regulatory Developments and Legislative Changes

Growth Opportunities Act Impact

The Growth Opportunities Act (Wachstumschancengesetz), which entered force on March 28, 2024, introduced fundamental changes to German transfer pricing rules for cross-border intra-group financing relationships 64. Section 1(3d) AStG now establishes specific requirements for debt sustainability and group credit rating considerations 65.

Under the new provisions, expenses from cross-border financing relationships within multinational groups may be deemed non-arm’s length if the taxpayer cannot demonstrate debt sustainability for the entire term and economic necessity for business purposes 66. Additionally, interest rates exceeding those available based on group credit rating may be challenged unless a derived stand-alone rating can be proven arm’s length 67.

Section 1(3e) AStG addresses intra-group arranging or forwarding of funds, establishing a rebuttable presumption that such activities constitute routine services 68. These provisions represent the first statutory codification of transfer pricing requirements for financing relationships in German law 69.

Amount B Implementation

The 2024 Administrative Principles incorporate the OECD’s Pillar One Amount B approach, providing a simplified and streamlined methodology for determining arm’s length routine profits for certain low-risk marketing and distribution activities 70. The German implementation clarifies that Amount B application is permissible for in-scope transactions, provided they involve covered jurisdictions with double taxation agreements and exclude non-cooperative jurisdictions under the German Anti-Tax Haven Act 71.

Amount B applies to business relationships involving goods purchased from group companies and subsequently resold to unrelated parties, with operating expense ratios falling within specified ranges of 3% to 20-30% depending on national implementation 72. The simplified approach utilizes a global pricing matrix containing fixed operating margins selected based on industry groupings and intensity factors 73.

Fourth Bureaucracy Relief Act Implications

The Fourth Bureaucracy Relief Act (BEG IV) fundamentally altered German transfer pricing procedural requirements by introducing mandatory automatic submission obligations and shortened deadlines 74. These changes reflect German authorities’ commitment to expediting tax audit processes while intensifying cooperation requirements for taxpayers 75.

The legislation specifically targets enhanced transparency and risk-based audit selection through the Transaction Matrix requirement 76. This structural change enables tax authorities to focus resources on high-risk transactions while streamlining routine compliance verification 77.

Advance Pricing Agreements and Dispute Resolution

German APA Programme Structure

Germany operates a comprehensive Advance Pricing Agreement programme administered by the Federal Central Tax Office (Bundeszentralamt für Steuern, BZSt) 78. APAs represent binding agreements between taxpayers and tax authorities that determine appropriate criteria for transfer pricing over specified periods, providing legal certainty for qualifying transactions 79.

The German APA process typically begins with a prefiling meeting to assess case qualification and evaluate probability of successful outcomes 80. German authorities explicitly reject unilateral APAs for cases involving tax treaty partners, requiring taxpayers to pursue bilateral arrangements initially 81. Access to APAs depends on various factors, including compliance with cooperation duties during tax audits and avoidance of preferential tax regimes 82.

Fee Structure and Timeline

German APA applications require payment of substantial fees, currently set at EUR 30,000 for transfer pricing cases, with reduced fees of EUR 10,000 for smaller transactions and EUR 7,500 for other cases 83. Prolongation applications incur additional fees of EUR 15,000, EUR 7,500, and EUR 3,750 respectively 84.

APA procedures typically extend over minimum periods of two to three years, reflecting the complexity of multilateral negotiations and comprehensive technical analysis requirements 85. German authorities have not established specific timing targets for APA completion, contributing to extended processing periods 86.

Mutual Agreement Procedures

Germany maintains an active mutual agreement procedure (MAP) programme for resolving transfer pricing disputes 87. Recent OECD statistics indicate Germany started 325 new transfer pricing MAP cases in 2023, representing approximately half of all new MAP cases initiated 88. During the same period, 285 transfer pricing MAP cases were successfully closed 89.

For German MAP initiation, taxpayers must submit formal and timely applications to the Federal Central Tax Office when double taxation threats emerge 90. No application fees apply for MAP procedures, and taxpayer participation typically ceases once procedures commence 91. Under applicable double taxation agreements with mandatory agreement clauses, resolutions must generally occur within two years 92.

EU Arbitration and Dispute Settlement

The EU Dispute Settlement Directive provides German taxpayers with additional dispute resolution mechanisms, including mandatory arbitration phases and transparent, enforceable timeframes 93. This directive has been transposed into German law, creating comprehensive frameworks for resolving double taxation disputes within European Union contexts 94.

German companies benefit from both traditional bilateral MAP procedures and enhanced EU arbitration mechanisms, providing multiple pathways for dispute resolution depending on specific circumstances and counterparty jurisdictions 95.

Audit Practices and Enforcement Trends

Contemporary Audit Focus Areas

German tax authorities have intensified transfer pricing audit activities, with recent surveys indicating significant focus on remuneration for supplies to distributors, affecting 61% of surveyed companies 96. Service transaction remuneration represents another major audit focus, impacting 46% of companies, particularly regarding benefit tests, shareholder costs, and pass-through arrangements 97.

Intangible asset licensing remuneration affects 45% of audited companies, with particular scrutiny of benefit tests, royalty rates, and royalty base determinations 98. Business restructuring transactions, including entity conversions to contract manufacturers or contract R&D entities, represent audit targets for 34% of companies 99. Financing arrangements, encompassing debit and credit interest rates and synergy benefit allocation for cash-pooling arrangements, affect 32% of audited entities 100.

Standard Audit Procedures

German tax auditors routinely request complete transfer pricing documentation covering all cross-border intercompany transactions as standard procedure 101. Following documentation review, auditors select specific transactions for detailed examination based on risk assessment criteria and materiality thresholds 102.

The introduction of the Transaction Matrix enables enhanced risk-based case selection, allowing authorities to allocate audit resources more effectively toward high-volume and complex transactions 103. This systematic approach represents a significant evolution in German audit methodology, emphasizing data-driven risk assessment and targeted examination procedures 104.

Business Restructuring Scrutiny

German authorities maintain particular focus on business restructuring transactions, especially those involving function transfers or significant changes in risk allocation 105. The revised Ordinance on Relocation of Functions has expanded qualifying fact patterns and implemented stricter exit tax valuation approaches 106.

These regulatory changes reflect German authorities’ commitment to preventing profit shifting through restructuring activities while ensuring appropriate compensation for transferred functions, assets, and risks 107. The enhanced scrutiny requires multinational enterprises to maintain comprehensive contemporaneous documentation supporting restructuring rationale and valuation methodologies 108.

Practical Compliance Considerations

Documentation Preparation Strategies

Given the compressed 30-day submission deadline, German companies must maintain audit-ready transfer pricing documentation throughout the year 109. This requirement necessitates proactive documentation strategies, including regular updates to benchmarking studies, maintenance of current functional and risk analyses, and preparation of Transaction Matrix templates 110.

Organizations should establish systematic documentation update cycles aligned with fiscal year-end procedures to ensure accuracy and completeness 111. The integration of Transaction Matrix preparation into routine transfer pricing processes represents a critical adaptation requirement for effective compliance management 112.

Technology and Data Management

The Transaction Matrix requirement emphasizes the importance of robust data management systems capable of generating structured, tabular overviews of intercompany transactions 113. Companies should invest in technology solutions that facilitate automated data compilation and standardized reporting formats 114.

Effective data management systems should accommodate multiple transaction types, various related party relationships, different transfer pricing methods, and comprehensive volume tracking capabilities 115. Integration with existing enterprise resource planning systems can streamline documentation preparation and enhance accuracy 116.

Cross-Border Coordination

German transfer pricing compliance requires careful coordination with related entities in other jurisdictions to ensure consistent approaches and avoid conflicting positions 117. This coordination becomes particularly important given Germany’s active MAP programme and potential for simultaneous examinations across multiple jurisdictions 118.

Organizations should establish clear protocols for information sharing, consistent methodological approaches, and coordinated response strategies for multi-jurisdictional inquiries 119. Proactive consideration of MAP and APA opportunities can provide valuable certainty for complex or high-value transactions 120.

Secondary Adjustments and Economic Analysis

German transfer pricing practice recognizes constructive dividends and hidden capital contributions as primary forms of secondary adjustments 121. Taxpayers should consider the broader economic implications of transfer pricing adjustments, including potential withholding tax consequences and impact on overall group tax positions 122.

Comprehensive economic analysis should encompass cash flow implications, potential double taxation risks, and opportunities for corresponding adjustments in related jurisdictions 123. This holistic approach enables more effective risk management and strategic planning for transfer pricing compliance 124.

The German transfer pricing regime represents one of the most comprehensive and sophisticated frameworks globally, combining detailed legislative requirements with extensive administrative guidance and robust enforcement mechanisms 125. The recent regulatory evolution, particularly the 2025 changes introducing shortened deadlines and enhanced documentation requirements, reflects Germany’s commitment to maintaining a leading position in international transfer pricing enforcement while providing clear guidance for compliant taxpayers 126.

Successful navigation of German transfer pricing requirements demands proactive compliance strategies, robust documentation systems, and careful attention to evolving regulatory developments 127. Organizations operating in Germany must adapt to the new regulatory environment while maintaining comprehensive approaches to transfer pricing analysis, documentation, and risk management 128.

  1. OECD, Transfer Pricing Country Profile Germany, December 2021, OECD Publishing
  2. Federal Ministry of Finance, Administrative Principles Transfer Pricing 2024, December 2024, BMF
  3. Grant Thornton, Germany Transfer Pricing Guide, 2020, Grant Thornton International
  4. KPMG, Transfer Pricing Documentation New Requirements in Germany, November 2024, KPMG International
  5. BDO, Transfer Pricing Documentation Rules, January 2025, BDO Germany
  6. Commenda, Germany Transfer Pricing Rules and Compliance, January 2025, Commenda
  7. Alvarez & Marsal, New German Administrative Principles for Transfer Pricing, January 2025, Alvarez & Marsal
  8. EY, Germany Issues Administrative Principles 2024 on Transfer Pricing, January 2025, Ernst & Young
  9. FGS, Germany Publishes Newly Updated Administrative Guidance on Transfer Pricing, June 2024, FGS
  10. RegFollower, Ministry of Finance Updates Transfer Pricing Guidelines for 2024, December 2024, RegFollower
  11. IBFD, New Circular on Application of Arm’s Length Principle, 2022, International Bureau of Fiscal Documentation
  12. BDO, New German Administrative Principles Transfer Pricing, 2021, BDO Germany
  13. Kroll, New Transfer Pricing Documentation and Submission Requirements Germany, March 2025, Kroll
  14. Gabler Wirtschaftslexikon, Gewinnabgrenzungsaufzeichnungsverordnung Definition, February 2018, Springer Gabler
  15. Grant Thornton, Germany Transfer Pricing Guide, 2020, Grant Thornton International
  16. BDO, Transfer Pricing Documentation Rules, January 2025, BDO Germany
  17. AGN, Transfer Pricing Documentation in Germany – A Topic for SMEs, April 2024, AGN International
  18. Grant Thornton, Germany Transfer Pricing Guide, 2020, Grant Thornton International
  19. Exactera, 13 Things to Know About Transfer Pricing in Germany, March 2025, Exactera
  20. OECD, Transfer Pricing Country Profile Germany, December 2021, OECD Publishing
  21. Grant Thornton, Germany Transfer Pricing Guide, 2020, Grant Thornton International
  22. OECD, Transfer Pricing Country Profile Germany, December 2021, OECD Publishing
  23. Grant Thornton, Germany Transfer Pricing Guide, 2020, Grant Thornover International
  24. Kreston, Germany’s New Transfer Pricing Rules, November 2024, Kreston Global
  25. BDO, Transfer Pricing Documentation Rules, January 2025, BDO Germany
  26. BDO, Transfer Pricing Documentation Rules, January 2025, BDO Germany
  27. Exactera, 13 Things to Know About Transfer Pricing in Germany, March 2025, Exactera
  28. BDO, Transfer Pricing Documentation Rules, January 2025, BDO Germany
  29. AGN, Transfer Pricing Documentation in Germany – A Topic for SMEs, April 2024, AGN International
  30. BDO, Transfer Pricing Documentation Rules, January 2025, BDO Germany
  31. Alvarez & Marsal, Federal Ministry of Finance Issued Guidance on Transaction Matrix, April 2025, Alvarez & Marsal
  32. BaseFirma, New Transfer Pricing Requirement in Germany Transaction Matrix, April 2025, BaseFirma
  33. TPA Global, Germany Introduces Mandatory Transaction Matrix, April 2025, TPA Global
  34. BaseFirma, New Transfer Pricing Requirement in Germany Transaction Matrix, April 2025, BaseFirma
  35. KPMG, Germany Transfer Pricing Documentation Requirements for Extraordinary Business Transactions, March 2025, KPMG
  36. KPMG, Germany Transfer Pricing Documentation Requirements for Extraordinary Business Transactions, March 2025, KPMG
  37. KPMG, Documentation of Extraordinary Transactions in Germany 2025, March 2025, KPMG Germany
  38. KPMG, Germany Transfer Pricing Documentation Requirements for Extraordinary Business Transactions, March 2025, KPMG
  39. Alvarez & Marsal, New Submission Deadlines for Transfer Pricing Documentation, November 2024, Alvarez & Marsal
  40. Kreston, Germany’s New Transfer Pricing Rules, November 2024, Kreston Global
  41. Kroll, New Transfer Pricing Documentation and Submission Requirements Germany, March 2025, Kroll
  42. TPA Global, Germany Introduces Mandatory Transaction Matrix, April 2025, TPA Global
  43. Alvarez & Marsal, New Submission Deadlines for Transfer Pricing Documentation, November 2024, Alvarez & Marsal
  44. Exactera, 13 Things to Know About Transfer Pricing in Germany, March 2025, Exactera
  45. Kroll, New Transfer Pricing Documentation and Submission Requirements Germany, March 2025, Kroll
  46. Kreston, Germany’s New Transfer Pricing Rules, November 2024, Kreston Global
  47. Baker McKenzie, Germany Tax Audit Orders and Submission Requests, December 2024, Baker McKenzie
  48. Kreston, Germany’s New Transfer Pricing Rules, November 2024, Kreston Global
  49. WW+KN, Role of Benchmarking Studies in Transfer Pricing, October 2024, WW+KN
  50. BDO, Transfer Pricing Documentation Rules, January 2025, BDO Germany
  51. TPA Global, Germany 2024 Transfer Pricing Guidelines, December 2024, TPA Global
  52. SSRN, German Federal Tax Court Rules in Favour of Taxpayer, February 2025, Social Science Research Network
  53. KPMG, Application Control Risk DEMPE Frameworks Germany, June 2023, KPMG International
  54. KPMG, Application Control Risk DEMPE Frameworks Germany, June 2023, KPMG International
  55. KPMG, Application Control Risk DEMPE Frameworks Germany, June 2023, KPMG International
  56. KPMG, Application Control Risk DEMPE Frameworks Germany, June 2023, KPMG International
  57. KPMG, Application Control Risk DEMPE Frameworks Germany, June 2023, KPMG International
  58. KPMG, Application Control Risk DEMPE Frameworks Germany, June 2023, KPMG International
  59. KPMG, Application Control Risk DEMPE Frameworks Germany, June 2023, KPMG International
  60. WW+KN, Role of Benchmarking Studies in Transfer Pricing, October 2024, WW+KN
  61. WW+KN, Role of Benchmarking Studies in Transfer Pricing, October 2024, WW+KN
  62. WW+KN, Role of Benchmarking Studies in Transfer Pricing, October 2024, WW+KN
  63. WW+KN, Role of Benchmarking Studies in Transfer Pricing, October 2024, WW+KN
  64. WTS, Germany New Transfer Pricing Rules for Cross-border Intra-group Financial Transactions, June 2024, WTS Global
  65. KPMG, Stricter Transfer Pricing Regulations for Intra-group Financing, July 2024, KPMG Germany
  66. WTS, Germany New Transfer Pricing Rules for Cross-border Intra-group Financial Transactions, June 2024, WTS Global
  67. EY, Germany Issues Administrative Principles 2024 on Transfer Pricing, January 2025, Ernst & Young
  68. EY, Germany Issues Administrative Principles 2024 on Transfer Pricing, January 2025, Ernst & Young
  69. WTS, Germany New Transfer Pricing Rules for Cross-border Intra-group Financial Transactions, June 2024, WTS Global
  70. FGS, Germany Publishes Newly Updated Administrative Guidance on Transfer Pricing, June 2024, FGS
  71. EY, Germany Issues Administrative Principles 2024 on Transfer Pricing, January 2025, Ernst & Young
  72. FGS, Germany Publishes Newly Updated Administrative Guidance on Transfer Pricing, June 2024, FGS
  73. Greenberg Traurig, OECD’s Amount B Simplified Transfer Pricing, March 2025, Greenberg Traurig
  74. KPMG, Transfer Pricing Documentation New Requirements in Germany, November 2024, KPMG International
  75. SSRN, New German Transfer Pricing Regulations on Business Restructurings, February 2025, Social Science Research Network
  76. TPA Global, Germany Introduces Mandatory Transaction Matrix, April 2025, TPA Global
  77. BaseFirma, New Transfer Pricing Requirement in Germany Transaction Matrix, April 2025, BaseFirma
  78. FGS, New Guidance on Germany’s APA Programme, June 2024, FGS
  79. BDO, Verständigungsverfahren und Advance Pricing Agreements, 2024, BDO Germany
  80. FGS, New Guidance on Germany’s APA Programme, June 2024, FGS
  81. FGS, New Guidance on Germany’s APA Programme, June 2024, FGS
  82. FGS, New Guidance on Germany’s APA Programme, June 2024, FGS
  83. OECD, Germany Dispute Resolution Profile, 2024, OECD Publishing
  84. BDO, Verständigungsverfahren und Advance Pricing Agreements, 2024, BDO Germany
  85. BDO, Verständigungsverfahren und Advance Pricing Agreements, 2024, BDO Germany
  86. FGS, New Guidance on Germany’s APA Programme, June 2024, FGS
  87. Alvarez & Marsal, German Transfer Pricing Observations Key Takeaways, January 2025, Alvarez & Marsal
  88. Alvarez & Marsal, German Transfer Pricing Observations Key Takeaways, January 2025, Alvarez & Marsal
  89. Alvarez & Marsal, German Transfer Pricing Observations Key Takeaways, January 2025, Alvarez & Marsal
  90. BDO, Verständigungsverfahren und Advance Pricing Agreements, 2024, BDO Germany
  91. BDO, Verständigungsverfahren und Advance Pricing Agreements, 2024, BDO Germany
  92. BDO, Verständigungsverfahren und Advance Pricing Agreements, 2024, BDO Germany
  93. BDO, Transfer Pricing Mutual Agreement Procedures and Advance Pricing Agreements, 2024, BDO Germany
  94. BDO, Transfer Pricing Mutual Agreement Procedures and Advance Pricing Agreements, 2024, BDO Germany
  95. KPMG, Company Audits and Dispute Resolution, March 2025, KPMG Germany
  96. International Tax Review, TP Dispute Trends in Europe, September 2024, International Tax Review
  97. International Tax Review, TP Dispute Trends in Europe, September 2024, International Tax Review
  98. International Tax Review, TP Dispute Trends in Europe, September 2024, International Tax Review
  99. International Tax Review, TP Dispute Trends in Europe, September 2024, International Tax Review
  100. International Tax Review, TP Dispute Trends in Europe, September 2024, International Tax Review
  101. International Tax Review, TP Dispute Trends in Europe, September 2024, International Tax Review
  102. International Tax Review, TP Dispute Trends in Europe, September 2024, International Tax Review
  103. Exactera, 13 Things to Know About Transfer Pricing in Germany, March 2025, Exactera
  104. TPA Global, Germany Introduces Mandatory Transaction Matrix, April 2025, TPA Global
  105. SSRN, New German Transfer Pricing Regulations on Business Restructurings, February 2025, Social Science Research Network
  106. SSRN, New German Transfer Pricing Regulations on Business Restructurings, February 2025, Social Science Research Network
  107. KPMG, Documentation of Extraordinary Transactions in Germany 2025, March 2025, KPMG Germany
  108. SSRN, New German Transfer Pricing Regulations on Business Restructurings, February 2025, Social Science Research Network
  109. Alvarez & Marsal, New Submission Deadlines for Transfer Pricing Documentation, November 2024, Alvarez & Marsal
  110. Kroll, New Transfer Pricing Documentation and Submission Requirements Germany, March 2025, Kroll
  111. TPA Global, Germany Introduces Mandatory Transaction Matrix, April 2025, TPA Global
  112. BaseFirma, New Transfer Pricing Requirement in Germany Transaction Matrix, April 2025, BaseFirma
  113. Alvarez & Marsal, Federal Ministry of Finance Issued Guidance on Transaction Matrix, April 2025, Alvarez & Marsal
  114. TPA Global, Germany Introduces Mandatory Transaction Matrix, April 2025, TPA Global
  115. Exactera, 13 Things to Know About Transfer Pricing in Germany, March 2025, Exactera
  116. BaseFirma, New Transfer Pricing Requirement in Germany Transaction Matrix, April 2025, BaseFirma
  117. KPMG, Company Audits and Dispute Resolution, March 2025, KPMG Germany
  118. Alvarez & Marsal, German Transfer Pricing Observations Key Takeaways, January 2025, Alvarez & Marsal
  119. BDO, Transfer Pricing Mutual Agreement Procedures and Advance Pricing Agreements, 2024, BDO Germany
  120. FGS, New Guidance on Germany’s APA Programme, June 2024, FGS
  121. Lund University, Secondary Transfer Pricing Adjustments, 2025, Lund University Publications
  122. Lund University, Secondary Transfer Pricing Adjustments, 2025, Lund University Publications
  123. Lund University, Secondary Transfer Pricing Adjustments, 2025, Lund University Publications
  124. KPMG, Company Audits and Dispute Resolution, March 2025, KPMG Germany
  125. Exactera, 13 Things to Know About Transfer Pricing in Germany, March 2025, Exactera
  126. TPA Global, Germany 2024 Transfer Pricing Guidelines, December 2024, TPA Global
  127. dhpg, New Administrative Principles on Transfer Pricing Published, January 2025, dhpg
  128. Kreston, Germany’s New Transfer Pricing Rules, November 2024, Kreston Global
Tags:
Table of Contents