New requirements for the transaction matrix according to Section 90 Paragraph 3 of the German Fiscal Code – What companies now need to consider
On April 2, 2025, the Federal Ministry of Finance published an information sheet on the transaction matrix as defined in Section 90 Paragraph 3 Sentence 2 Number 1 of the German Fiscal Code (AO). Since January 1, 2025, this transaction matrix has been a mandatory component of the transfer pricing documentation for companies with cross-border business relationships with related parties or permanent establishments.
What is it about?
The transaction matrix is a structured, tabular overview that summarizes all relevant information on intra-group, cross-border business transactions. It serves, in particular, to support risk-oriented selection and review during tax audits. The mandatory information includes, among other things:
- Subject matter and nature of the business transactions (e.g., delivery of goods, services)
- Participating parties, including details of the service providerin and recipientin
- Volume and fees of business transactions (in euros)
- Contractual basis (contract title)
- Transfer pricing methods used (e.g., cost-plus method)
- Affected tax jurisdictions
- Indications of deviations from standard taxation (e.g. preferential tax regimes)
The tax authorities may, in justified cases, permit deviations in the form, content, or scope of the transaction matrix. Existing agreements with the tax authorities may be taken into account.
Who is this relevant for?
The obligation to prepare and submit a transaction matrix applies to all companies that maintain business relationships with affiliated companies or branches abroad and are therefore subject to transfer pricing documentation. This topic is particularly relevant for tax departments, finance managers, and consultants.inside, the clientto provide internal support in the area of transfer pricing.
What should be considered during tax audits?
As of January 1, 2025, a 30-day deadline applies to tax audits: After notification of the audit order, the master documentation, records of extraordinary business transactions, and the transaction matrix must be submitted within 30 days – without a separate request from the tax authorities. This also applies to audit periods prior to 2025, provided the audit order is issued in 2025.
If the transaction matrix is not submitted on time, a surcharge of 5.000 euros must be imposed (§ 162 para. 4 AO).
Recommendation for practical application
We recommend adapting internal processes for documenting intra-group transactions to the new requirements at an early stage and establishing the transaction matrix as a fixed component of transfer pricing documentation. If there is any uncertainty regarding the structure or if agreements with the tax authorities already exist, you should contact the relevant authority as soon as possible.
We are happy to provide you with further information and individual support in the area of transfer pricing and tax compliance.
