In Bloomberg's "2025 Transfer Pricing Forum,"
Director Tom Braukmann and Managing Director Philip de Homont
provide insights into the interaction between transfer pricing and
customs valuation practices in Germany. They explain how the German
tax and customs authorities operate separately but with rigorous
frameworks to ensure compliance and combat avoidance.
The authors discuss the legal framework in Germany and highlight
pitfalls between transfer pricing at arm's length and customs
transaction value methods. They address challenges multinational
enterprises face when aligning transfer pricing adjustments with
customs duties, especially following year-end reviews.
Additionally, the article covers supply chain restructuring
strategies multinational entities may apply to mitigate customs
duties, while explaining how Germany's comprehensive anti-abuse
rules and relocation of functions legislation scrutinize such
changes for economic substance and tax accuracy.
