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      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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      GTPS News: Current Insights

      S/4HANA implementations: Why transfer pricing should be considered from the outset
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      Special rules on loss set-offs and late-payment interest in the ongoing tax audits relating to the Covid years
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      OECD data for 2024 highlight the significance, success rates and duration of MAPs and APAs.
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      Practical Guide to Benchmark Studies, Data Availability and Financial Updates
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      MAP Outcomes: When Does Section 153(4) AO Apply to Transfer Pricing?
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      The increasing shift of work activities to domestic and cross-border home office settings, as well as to mobile working arrangements, necessitates a reassessment of traditionally rigid tax structures.
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      How tax authorities use interest adjustment and prepayment clauses to shorten loan maturities.
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      Consistently positive cash pool balances are coming under increasing scrutiny in German tax audits.
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      Example cases on the applicability of Section 153 (4) AO to transfer pricing cases
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      The BMF published a revised version of its guidance on mutual agreement and arbitration procedures on 24 September 2025.
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      Current case law on the transfer of functions in Germany - risks at a glance.
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      Practical guidance on the treatment of compensatory payments following off balance sheet adjustments under Section 1 AStG
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      BFH confirms disclosure obligation for tax-relevant emails – key points for taxpayers.
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      New options for year-end adjustments in the transfer pricing field.
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      Legislators and tax authorities intensify scrutiny of cash pool participants – what companies need to consider.
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      Transaction Matrix: An automation can ease transfer pricing compliance and reduce tax audit risk.
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      BFH reviews application of the income correction standard § 1 AStG by the tax office
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      Stricter regulations on the relocation of functions in Germany - tax risks at a glance.
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      Written form contracts - transfer pricing advice
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      What to look out for from a transfer pricing perspective in the case of permanent losses in Germany.
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      Does the introduction of Section 153 (4) AO mean that agreements from previous audits must be continued in future tax returns?
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      Is it justified to tax licensing and sales transactions whose only link to Germany is registration?
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      Can reliable comparative values be determined from purchase price allocations?
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      How can the costs of centralised services be correctly allocated for tax purposes?
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      Offsetting of trademark licence fees in the focus of tax audits
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      New rules from 2025 require rapid submission of documentation without a specific request.
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      Appropriateness of fees and possible transfer pricing risks
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      Tax authorities scrutinise the amount of value added and audit permanent establishments.
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      Further content

      Responding to global change and digital disruption
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      We have specialised in tax solutions for the design of transfer pricing systems.
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      Cloud-based solution for calculating the global minimum tax
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      Utilizing operational transfer pricing to move from a manual mess to an automated success!

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      Your contact

      Michael Freudenberg
      Michael Freudenberg

      Partner, Tax - Head of Global Transfer Pricing Services

      KPMG AG Wirtschaftsprüfungsgesellschaft