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The Federal Ministry of Finance (BMF) published an information sheet on the new transaction matrix introduced at the end of October 2024 with the Fourth Bureaucracy Relief Act as a new component of transfer pricing documentation. The transaction matrix is a structured, tabular overview that contains relevant information on the taxpayer's cross-border business relationships with related parties and permanent establishments (PEs).

The BMF also issued guidance on reporting the details of a fiscally transparent partnership in the country-by-country (CbC) report pursuant to Section 138a of the German Tax Procedure Law and for the CbC reporting safe harbor pursuant to Section 84 of the German Minimum Tax Act. The guidance is applicable to financial years beginning after December 31, 2023.

Read a  prepared by the ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø member firm in Germany

Other recent tax developments in Germany include:

• The coalition agreement includes many tax policy measures. Read TaxNewsFlash
• The Federal Tax Court (BFH) decided two partially identical cases involving the existence of a tax group in the case of atypical silent partnerships (I R 33/22 and I R 17/21).
• The Constitutional Court on March 26, 2025, rejected a constitutional complaint against the Act on the Reduction of the Solidarity Surcharge 1995 (dated December 10, 2019) (2 BvR 1505/20).
• The BMF on March 24, 2025, issued guidance on the interest limitation rule to reflect changes under the so-called Secondary Credit Market Promotion Act of 22 December 2023.