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.

The Correspondence Principle And Hidden Capital Contributions In Cross-border Cases

Germany's Federal Tax Court has ruled on the limits of the correspondence principle in corporate tax law, addressing whether tax authorities can adjust a company's taxable income when a shareholder's deemed gain...

AO

A&O Shearman

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

AM

Alvarez & Marsal

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

FG

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

FG

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

RS

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

Passive Entstrickung Infolge DBA-Änderung – Anwendungsbereich Und Besteuerungszeitpunkt Nach BFH

P

POELLATH

Deals Still Get Done – But Only With A New Playbook

Germany Finance

SR

McDermott Will & Schulte

Das Gewerbesteuerliche Schachtelprivileg Bei (Qualifiziertem) Anteilstausch – Keine Anrechnung Der Vorbesitzzeiten Des Übertragenden Rechtsträgers

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POELLATH

Trial Starts Of Brothers Suspected Of Russian Exports Of Engineering Equipment

Germany International

DM

Duane Morris LLP

LD Düsseldorf, May 7, 2026, Refusal Of Provisional Measures, UPC_CFI_1927/2025, 1928/2025

BP

Bardehle Pagenberg

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

Our Advisory explores the potential impact of the German government's draft amendment to the real estate transfer tax law.

Germany Real Estate

AP

Arnold & Porter

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

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

P

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?

P

PricewaterhouseCoopers

New German Documentation Requirements for Transfer Pricing

Today, about 30 countries have requirements on the legal documentation of transfer pricing, which have, in some countries, existed for many years. Germany first adopted legal provisions in 2003. The new legal provisions were necessitatedby a decision made by the German supreme tax court in 2001.

MW

McDermott Will & Emery

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.

P

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?

Germany Strategy

MB

Mayer Brown

240. Key Transfer Pricing Statute Void Under EU Law?

KG

KPMG Germany

239. New Deal For German Transfer Pricing

KG

KPMG Germany

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Latest Videos

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Grant Thornton Société d’Avocats

Tax Webcast March 2018 (Video)

DC

Deloitte Cyprus

Transfer Pricing in Luxembourg

AM

Arendt & Medernach

Transfer Pricing In A Post BEPS World, With Alain Goebel At AFLF 2017 (Video)

AM

Arendt & Medernach

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

AM

Arendt & Medernach

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