Transfer pricing
The goal is: to avoid back taxes and breaches of duty
The implementation of regulatory requirements on transfer pricing will be one of the major future challenges for companies. The digitization of data is playing an increasingly central role and with it the networking of tax administrations
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On May 15, 2025, the Federal Ministry of Finance (BMF) published the "Fact sheet on cross-border audit cooperation with tax administrations of other countries and territories: joint and simultaneous audits and presence of officials".
The Federal Ministry of Finance has published an implementation guide for the new transaction matrix.
On April 3, 2025, the US government announced the introduction of a general 10% base tariff and 20% additional tariff on all imports, including those from Europe and Germany.
The Federal Ministry of Finance has published a discussion draft for a Minimum Tax Adjustment Act (MinStGAnpG). The main aim of the law is to make the application of the CbCR safe harbour more specific.
The submission deadlines in Italy for tax returns for the 2023 assessment period have changed several times this year, currently to October 31, 2024.
With the DAC7 Implementation Act, shortened deadlines for the submission of records in accordance with Section 90 (3) AO (transfer pricing documentation) were already introduced at the end of December 2022 by means of a new Section 90 (4) AO.
Basics, design and documentation: With the "Transfer Pricing" seminar series, the Maschinenbau-Institut offers you practical tools to successfully complete your transfer pricing project.
On July 17, 2023, the German Federal Ministry of Finance presented a draft bill of the so-called Growth Opportunities Act, which, among other things, provides for a new regulation of the deductibility of interest (as of January 1, 2024).
The VDMA's regional associations have a long tradition of organizing tax events. We will be offering these events again in the first half of 2024. We give you a small preview of when and where!
The BMF published its revised Administrative Principles Transfer Pricing 2023 (VG VP 2023) on June 6, 2023.
Brazil will in the future follow the OECD Transfer Pricing Guidelines, thus turning away from the previous special regime.
The steep rise in interest rates in recent months has direct consequences for intergroup transfer prices and will be the focus of future tax audits.
In the future, taxpayers will be required to submit their transfer pricing documentation without a request within 30 days of being notified of the audit order.
In 2022, the new regulation for Transfer of Functions (FVerlV) came into force. The submission deadline of transfer pricing documentation will be dramatically shortened from Jan. 1, 2025.
The German Federal Ministry of Finance (BMF) plans to shorten the submission deadline.
On 05.07.2022, the BMF published the draft bill of a new function shifting regulation ("FVerlV-E").
On January 20, 2022, the OECD published the 2022 version of the OECD Transfer Pricing Guidelines (TPG).
The BFH reaffirms the priority application of the price comparison method.
For the first time, the OECD is providing valuable interpretive guidance on transfer pricing practice for the arm’s-length valuation of controlled financial transactions.
In the period from 10.12.2019 to 14.7.2021, the German Federal Ministry of Finance (BMF) has continuously pushed for a "reform" of the German transfer pricing rules.
The Austrian Ministry of Finance published the draft assessment of the revised Austrian Transfer Pricing Guidelines 2021 on the BMF website on Dec. 4, 2020.
From Excel sheet to optimized transfer pricing system
From theory to practical implementation.
Tools for the implementation of a transfer pricing project.
Poland has adjusted its transfer pricing regulations twice in the last 5 years and tax audits can include three different regimes. Taxpayer should carefully align periods with different requirements.
On 3 December 2020, the Federal Ministry of Finance (BMF) published Administrative Principles 2020 (VG 2020) on obligations to cooperate and estimation of tax bases.
A compact introduction to the basics of tax transfer pricing.
In a light-footed manner, the book "Quantitative Transfer Pricing" presents one of the most important topics in international tax law.
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