Transfer pricing regulations
In-depth analysis: Legal basis of business premises
According to the new BMF letter of 18.06.2026, the legal [...]
17.07.202611 minThe definition of a permanent establishment according to the German Federal Ministry of Finance (BMF) letter of June 18, 2026 – practical guidance
The BMF letter of June 18, 2026, fundamentally defines the administrative principles regarding the concept of a permanent establishment [...]
16.07.202611 minThe UN Manual on Transfer Pricing
The United Nations Practical Manual on Transfer Pricing for Developing [...]
09.04.20268 minOECD's 'Risk-over-Control' approach
Risk-based approach to transfer pricing – how to practically apply the arm's length principle [...]
13.03.20267 minThe Profit Allocation Recording Ordinance – GAufzV
GAufzV – What companies need to know about documenting their transfer prices [...]
02.03.20267 minSection 1 of the Foreign Tax Act: Scope and content explained in an easy-to-understand way
Section 1 of the Foreign Tax Act (AStG) is the central provision for [...]
02.03.20263 minDraft BMF letter on the definition of permanent establishment
Draft of a BMF letter on the concept of a permanent establishment and its justification in domestic and international tax law
13.02.20267 minAdministrative Principles on Transfer Pricing 2024 of 12 December 2024
New BMF guidelines on arm's length comparison, documentation and "Amount B" – relevant for cross-border transfer pricing.
07.02.20262 minInformation sheet on the transaction matrix
Mandatory component of the transfer pricing documentation: Transaction matrix with a 30-day deadline – otherwise a surcharge of €5.000 applies.
10.10.20252 minBEFIT – Framework for Corporate Taxation in Europe
BEFIT framework for corporate taxation in Europe – which is based on [...]
12.08.20255 min
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