Germany: Draft legislation on submission of transfer pricing documentation in tax audit
Proposed to become effective 1 January 2023
Draft legislation on submission of transfer pricing documentation
The Federal Ministry of Finance (BMF) published draft legislation on the modernization of the tax procedures law that would provide that in the event of a tax audit, transfer pricing documentation would be required to be submitted (i.e., without a separate request by the tax authority). In addition, the deadline would be shortened to 30 days from the date of the disclosure of the audit order, instead of 60 days
The draft legislation is proposed to become effective 1 January 2023.
The draft legislation will be forwarded to the upper house of the German parliament (Bundesrat) for consideration and then to the lower house of the German parliament (Bundestag) for consideration. Thus, it is possible that amendments to the draft legislation will be made.
Read an October 2022 report [PDF 259 KB] prepared by the KPMG member firm in Germany
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