Subscribe to KPMG's "German Transfer Pricing Insights"

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.

29-08-2025 - The highest Federal Fiscal Court (BFH) has confirmed in two rulings that Section 1 (5) AStG is an income correction norm and not an independent regulation for determining permanent establishment profits. In particular, the norm does not allow the determination of the profits of a dependent permanent establishment to be rejected without further investigation in the context of the limited tax liability of a foreign corporation.

29-08-2025 - The German regulations on transfer of functions present new challenges for internationally operating companies: With tightened requirements that go beyond OECD guidelines, this topic is increasingly coming into focus during tax audits and is sparking debate between taxpayers and the tax authorities. Our article highlights the latest developments and explains what companies should pay particular attention to in order to identify potential tax tripping hazards at an early stage.

29-08-2025 - The Federal Constitutional Court has made important clarifications in a recent decision regarding the requirement of a written form for intercompany agreements as a prerequisite for the arm's length principle.

29-08-2025 - Companies that generate losses over a longer a period of time face a higher risk of being scrutinized by tax authorities in Germany with regards to their adherence to the arm’s length principle.