This article from Bloomberg BNA’s Transfer Pricing International Journal examines the current German transfer pricing landscape. One of the most important changes in recent times has been a considerable reinforcement of “substance over form” requirements. While this is in line with general transfer pricing trends, this particular court ruling had been surprising to many, because it overturned a long standing “truth” of German transfer pricing conduct: the strict requirement of formal written agreement between transfer pricing parties. In the future, German tax authorities will be severely limited in applying purely formulistic arguments to transfer pricing cases. The relevant court decision was made in October 2012, when the highest German tax court passed a landmark decision on “substance over form,” but was only published in 2013.