Germany: Transfer Pricing

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

Transfer Pricing And Customs Valuation: Navigating Germany's Regulatory Landscape In 2025

In Bloomberg's "2025 Transfer Pricing Forum," Director Tom Braukmann and Managing Director Philip de Homont provide insights into the interaction between transfer pricing and customs valuation practices in Germany.

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NERA

German TP Update: Amended Guidance On International Mutual Agreement And Arbitration Procedures

On 24 September 2025, the German Federal Ministry of Finance (Bundesfinanzministerium) published an updated version of the guidance on International Mutual Agreement and Arbitration Procedures...

AM

Alvarez & Marsal

Landmark Decision On Start-Up Loss Allocation And Substance-Over-Form In Transfer Pricing: Key Insights For Transfer Pricing And Legal Practitioners

On May 27, 2025, the German Federal Constitutional Court (Bundesverfassungsgericht) issued a landmark ruling (Case No. 2 BvR 172/24) concerning the deductibility of start-up losses within intercompany transactions...

AM

Alvarez & Marsal

Overview Of The BMF Instruction Sheet On Cross-Border Audit Cooperation

German Federal Ministry of Finance (BMF) recently released an instruction sheet on cross-border audit cooperation with tax administrations of other countries (dated May 15, 2025).

AM

Alvarez & Marsal

BFH: A Permanent Establishment Is Not An Employer Under Tax Convention Law

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Flick Gocke Schaumburg

Tax-Savvy Selling: Getting Exit-Ready The Right Way

AM

Alvarez & Marsal

New Guidance On Germany's APA Programme For Transfer Pricing Purposes

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Flick Gocke Schaumburg

Annual Tax Act 2024: Foreign Retirement Plan Reforms

FG

Flick Gocke Schaumburg

New Transfer Pricing Rules May Limit Interest Deduction In Inbound Cases

AM

Alvarez & Marsal

OECD Publishes Additional Guidance On The S&S Approach (Pillar One Amount B)

LL

Loyens & Loeff

Transfer Pricing: Significant Tightening For Financial Transactions And Services

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RSM Ebner Stolz

Geplante Änderungen Des DBA Deutschland-Schweiz

BK

Bär & Karrer

New Case Law On The Determination Of Arm's Length Interest Rates For Intercompany Loans

Germany Commercial

WG

WTS Global

Why Share Deals Are Becoming More Difficult For Entrepreneurs (German)

Germany Real Estate

AP

Arnold & Porter

Class Actions Radar: Germany

Germany Litigation

KL

Herbert Smith Freehills Kramer LLP

German Government Adopted The Law On CO₂ Storage And Utilisation

Germany Environment

KL

Herbert Smith Freehills Kramer LLP

Strengthening Employee-Driven Innovation At Munich Airport

Germany Employment

innosabi

Prosecution Seeks 5 Year Jail Term For Sanctions Violation Ringleader

Germany International

DM

Duane Morris LLP

Alvarez & Marsal Webinar: European Restructuring And Corporate Distress In 2025 (Video)

Germany Insolvency

AM

Alvarez & Marsal

Breaking Down The German Royalty Barrier - A View From Ireland

Germany has introduced measures to limit the deductibility of royalties paid by German resident taxpayers to related parties in certain circumstances.

M

Matheson

Upcoming New Dividend Stripping Tax Rules Regarding Trades With German Stock Over The Record Date

According to market sources, the German Ministry of Finance is going to issue a draft tax bill covering new rules on the tax treatment of so-called cum/cum transactions shortly before Christmas.

MB

Mayer Brown

Doing Business In Germany - Overview On Taxation

Local tax offices administer the income tax to be paid by individuals, corporate income tax, as well as value added tax (VAT) and real estate transfer tax.

SP

Squire Patton Boggs

Transfer Pricing Of Intangibles

The development, transfer, and licensing of intangibles are part and parcel of cross-border transactions among related parties. The allocation of costs and revenues, risks and chances, has a fundamental impact on the tax liability of multinational companies.

JD

Jones Day

German Transfer Pricing Rules In Practice

JD

Jones Day

Legal Problems Arising in the Course of the Transfer of Credit Portfolios Can be Solved

Germany Finance

MB

Mayer Brown

German Tax & Legal News - November 2004

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PricewaterhouseCoopers

New Documentation Obligations in Germany For International Transfer Pricing

JD

Jones Day

German Tax & Legal News - September 2004

Germany International

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PricewaterhouseCoopers

New German Documentation Requirements for Transfer Pricing

MW

McDermott Will & Emery

German Tax & Legal News - August 2004

Germany Media & IT

P

PricewaterhouseCoopers

Supreme Tax Court Refuses Income Adjustment Re Interest-Free Loan To Finance Foreign PE

P

PricewaterhouseCoopers

Can German Taxable Income Be Determined On A Cost-Plus Basis?

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PricewaterhouseCoopers

The Draft Block Exemption Regulation on Technology Transfer Agreements – Is the New Safe Harbor Less Safe?

Germany Strategy

MB

Mayer Brown

German Tax & Legal News - August 2004

Issues relating to German Tax & Legal News

Germany Media & IT

P

PricewaterhouseCoopers

Supreme Tax Court Refuses Income Adjustment Re Interest-Free Loan To Finance Foreign PE

The Supreme Tax Court has held that a loan from a domestic shareholder to a domestic subsidiary to fund a foreign PE is not a foreign transaction open to income adjustment under the transfer pricing rules.

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PricewaterhouseCoopers

Can German Taxable Income Be Determined On A Cost-Plus Basis?

The cost-plus method is one of the three transfer pricing methods accepted by the German tax authorities. (The other two are the comparable uncontrolled price method and the resale price method.)

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PricewaterhouseCoopers

The Draft Block Exemption Regulation on Technology Transfer Agreements – Is the New Safe Harbor Less Safe?

On 1 October 2003, the European Commission published its draft block exemption Regulation on the application of Article 81(3) EC Treaty to technology transfer agreements¹ ("Draft TTBER").

Germany Strategy

MB

Mayer Brown

German Tax and Legal News - May 2004

Germany Strategy

P

PricewaterhouseCoopers

239. New Deal For German Transfer Pricing

KG

KPMG Germany

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Arendt & Medernach

Développement Durable : Les Enjeux Juridiques Et Fiscaux (Video)

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Grant Thornton Société d’Avocats

Tax Webcast March 2018 (Video)

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Deloitte Cyprus

Transfer Pricing in Luxembourg

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Arendt & Medernach

Transfer Pricing - Is Your Pricing Still Arm's Length? (Video)

AM

Arendt & Medernach

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