In this article from BNA’s Transfer Pricing International Journal, NERA Special Consultant Dr. Alexander Voegele and Jean-Benoit Voegele review the transfer pricing and international tax developments that transpired in Germany in 2010 and assess the outlook for 2011. The authors note that 2010 was primarily dominated by discussion of the guidelines on the relocation of functions, as the final guidelines on this subject were published on 13 October 2010 and comprised some 81 pages, including a multitude of examples and cases. The authors expect that discussion in 2011 will also focus primarily on these guidelines, as well as on the attribution of income to headquarters and permanent establishments, the use of foreign losses, and the improvement of competent authority procedures.