The cost-plus method is one of the three transfer pricing methods accepted by the German tax authorities. (The other two are the comparable uncontrolled price method and the resale price method.)

The Supreme Tax Court has held that a loan from a domestic shareholder to a domestic subsidiary to fund a foreign PE is not a foreign transaction open to income adjustment under the transfer pricing rules.

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.

In a series of rulings in 2019 and 2020, the German Federal Fiscal Court has abandoned its decades-long ruling practice on implicit group support and the blocking effect of para.

Today, about 30 countries have requirements on the legal documentation of transfer pricing, which have, in some countries, existed for many years. Germany first adopted legal provisions in 2003. The new legal provisions were necessitatedby a decision made by the German supreme tax court in 2001.

Selling a business is a complex endeavor—strategically, operationally, and above all, from a tax perspective. In many cases, serious tax preparation...

The European Commission has proposed a Code of Conduct for all procedures under the Arbitration Convention with the object of avoiding double taxation on intra-community trade.

Germany's Federal Tax Court has ruled on the limits of the correspondence principle in corporate tax law, addressing whether tax authorities can adjust a company's taxable income when a shareholder's deemed gain...

On 22 March 2024, the Ger­man Fe­deral Coun­cil ap­pro­ved the Me­dia­tion Com­mit­tee's com­pro­mise pro­po­sal on the Growth Op­por­tu­nities Act.

According to market sources, the German Ministry of Finance is going to issue a draft tax bill covering new rules on the tax treatment of so-called cum/cum transactions shortly before Christmas.

On 24 September 2025, the German Federal Ministry of Finance (Bundesfinanzministerium) published an updated version of the guidance on International Mutual Agreement and Arbitration Procedures...

Germany's Annual Tax Act 2024 (Jahressteuergesetz) brings tweaks to the country's Income Tax Act (Einkommensteuergesetz). Due to adjustments to Sec. 22 no. 5 sentence 2 of the act...

Germany has introduced measures to limit the deductibility of royalties paid by German resident taxpayers to related parties in certain circumstances.

In its decisions of 12 December 2024 (VI R 25/22, VI R 26/22 and VI R 27/22) published on 17 April 2025, the Federal Tax Court (Bundesfinanzhof – BFH) dealt with the classification of a foreign permanent establishment as an employer under tax convention law.

The Growth Opportunities Act (Wachstumschancengesetz), effective from March 28, 2024, introduced major revisions to Germany's transfer pricing regulations for intercompany financing.

Although many legal aspects have to be observed within the course of the sale of distressed loans, there are no legal obstacles in Germany which would bar such sales.

Our Advisory explores the potential impact of the German government's draft amendment to the real estate transfer tax law.

The German tax authorities (GTA) have updated their administrative explanations on Advance Pricing Agreements (APAs) providing guidance on how they interpret the APA legislation and operate the German APA Programme.

German Federal Ministry of Finance (BMF) recently released an instruction sheet on cross-border audit cooperation with tax administrations of other countries (dated May 15, 2025).