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.
Read also in the Transfer Pricing Year in Review: What shaped 2025 - and what 2026 will bring
The new KPMG report "2025 Transfer Pricing Year in Review" highlights the most important developments of the past year and provides an outlook on how companies can prepare for 2026.
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Michael Freudenberg
Partner, Tax - Head of Global Transfer Pricing Services
KPMG AG Wirtschaftsprüfungsgesellschaft
Current insights
Obligation to Disclose Emails in Tax Audits
28-11-2025 - The German Federal Fiscal Court (Bundesfinanzhof, BFH) ruled on 30 April 2025 (Case No. XI R 15/23) that tax-relevant emails must be disclosed during tax audits. This article explains the requirements, how the taxpayer’s qualification right works, associated risks, and practical recommendations.
German Cash Pool Participants in the Focus of Legislators and Tax Authorities
28-11-2025 - Legislators and tax authorities are increasingly focusing on German participants in cross-border cash pools. What do the stricter legal requirements and the intensified audit practices mean for pricing, documentation, and functional analysis? This article provides guidance on how to prepare for the next tax audit.
Year-End Adjustment Quo Vadis?
28-11-2025 - Transfer pricing adjustments at the end of the year often encounter acceptance problems abroad (from a German perspective). This is particularly the case when the profit margin of a routine company shall be reduced. A recent ruling by the Court of Justice of the European Union could offer new options for action.
Single Source of Truth for Intercompany Transactions: An Automated Transaction Matrix
28-11-2025 - Starting January 2025, the so-called “transaction matrix” will be a mandatory component of transfer pricing documentation for multinational enterprises in Germany. This new regulation, introduced through the Fourth Bureaucracy Relief Act, requires companies to submit a structured overview of all cross-border transactions with related parties within 30 days after the announcement of a tax audit.
