Tax – The One Pager: Amendment to Transfer Pricing Documentation Requirements
19. November 2024
Tax – The One Pager: Amendment to Transfer Pricing Documentation Requirements19. November 2024 On October 18, 2024, the German Bundesrat (upper house) approved the Fourth Bureaucracy Relief Act (BT-Drs. 20/11306). The law aims at simplifying transfer pricing documentation requirements. Current legal situationAll documentation (local file, master file, documentation of extraordinary business transactions) must be submitted within 30 or 60 days after request by the tax audit department (“GTA”) (sec. 90 (3) sent. 1, 3, 7 et seqq. General Fiscal Code (Abgabenordnung; “AO”)). AmendmentsIn addition to the documentation of facts and an economic analysis, local files are to include a transaction matrix going forward. Furthermore, the submission requirements for the start of tax audits are to change:
Regulatory backgroundGoing forward, GTA is to use a risk-based approach in tax audits and limit its request to a local file to transactions that warrant examination. A reduced documentation burden means a relief for taxpayers. Relevance for practice
Key takeawaysAfter the amendment of sec. 90 (3) AO, the following applies to taxpayers:
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