The importance of tax transfer pricing is increasing. Globalisation and initiatives at OECD (BEPS) and EU level are increasing complexity. In addition, the regulatory framework for transfer pricing is constantly changing.
With our new newsletter "German TP Insights", we inform you quarterly about developments in the area of transfer pricing in Germany. Our articles deal with current regulatory changes, experience reports from tax audits and other relevant topics in the field of transfer pricing.
We hope you like the new format and look forward to your feedback.
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Michael Freudenberg
Partner, Tax - Head of Global Transfer Pricing Services
KPMG AG Wirtschaftsprüfungsgesellschaft
Current insights
Brand licensing fees in the focus of tax audits
27.03.2025 - The allocation of licensing fees for trademark rights is increasingly coming under scrutiny by German tax authorities during tax audits. In particular, inbound trademark allocations – i.e. payments made by companies based in Germany to affiliated foreign entities for the use of trademark rights – are subject to heightened examination.
Category: Transfer pricing
Documentation of extraordinary transactions in Germany 2025
27.03.2025 - This article gives a brief overview of the German transfer pricing documentation regulations that focus on extraordinary business transactions, especially in the light of the new 2025 documentation requirements. The previous German documentation regulations up to 2024 relating to extraordinary business transactions were already stricter than for the documentation of ordinary transactions.
Category: Transfer Pricing
Upstream guarantees from a German TP perspective
27.03.2025 - Upstream guarantees provided by German taxpayers to a foreign shareholder in connection with providing collateral for loans granted by banks to the parent can entail transfer pricing risks if no appropriate guarantee fee is foreseen. The article examines the appropriateness of a guarantee fee based on merit and amount as well as the consequences if no guarantee fee is charged.
Category: Transfer pricing
Field report: data centers in the focus of tax audits
27.03.2025 - German tax authorities are increasingly focusing on the use of data centers set up in Germany by international technology corporate groups. In particular, the value-added contributions of intra-group data centers in Germany are being questioned, particularly in connection with tax audits conducted by the Federal Tax Audit Office.
Category: Transfer pricing
