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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. They explain how the German tax and customs authorities operate separately but with rigorous frameworks to ensure compliance and combat avoidance.
The authors discuss the legal framework in Germany and highlight pitfalls between transfer pricing at arm's length and customs transaction value methods. They address challenges multinational enterprises face when aligning transfer pricing adjustments with customs duties, especially following year-end reviews.
Additionally, the article covers supply chain restructuring strategies multinational entities may apply to mitigate customs duties, while explaining how Germany's comprehensive anti-abuse rules and relocation of functions legislation scrutinize such changes for economic substance and tax accuracy.
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