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The importance of tax transfer pricing is increasing. Globalisation and initiatives at OECD (BEPS) and EU level are increasing complexity. In addition, the regulatory framework for transfer pricing is constantly changing.

With our new newsletter "German TP Insights", we inform you quarterly about developments in the area of transfer pricing in Germany. Our articles deal with current regulatory changes, experience reports from tax audits and other relevant topics in the field of transfer pricing.

We hope you like the new format and look forward to your feedback.

30.05.2025 - With the introduction of Section 153(4) of the German Fiscal Code (AO), German taxpayers face new challenges as the notification and correction obligations have been expanded. The new regulation raises questions, particularly regarding transfer pricing, which is often settled through compromises during audits. It remains unclear whether agreements from previous audits must be continued in future tax declarations and whether such agreements can be legally confined to the current audit period. The article provides an overview of the new requirements and highlights practical aspects of applying Section 153(4) AO to transfer pricing issues.

30.05.2025 - In 2020, a German tax regulation with international significance became the focus of intense discussions. The regulation concerns the limited tax liability on the granting of rights that are registered in a domestic registry. This provision, which has existed for almost 100 years and is anchored in Section 49 (1) No. 2f sentence 6 EStG, raises essential questions: Is it justified to tax licensing and IP transfers whose only connection to Germany is the registration of the right? In our current article, we display the background and ongoing discussions surrounding this significant issue.

30.05.2025 - In the context of corporate acquisitions, companies are typically required to prepare a Purchase Price Allocation (“PPAâ€�). The PPA allocates the total consideration paid for the acquired business to its identifiable assets and liabilities based on their fair market values at the acquisition date. While the PPA serves for accounting purposes, it often includes valuations of intangible assets, which raises an important question: Can a PPA be used as a reliable basis for determining arm’s length prices in subsequent intercompany transactions?

30.05.2025 - International operating groups often centralize administrative services to save costs and benefit from standardized processes. One challenge lies in the correct fiscal allocation of costs, as these services often benefit multiple companies within the group. In particular, in inbound cases, the fees for centralized services are regularly challenged by the German tax authorities. This article provides recommendations and a practical example regarding bundled service allocation at the parent company.