In 2014, Germany experienced a major shift in its transfer pricing landscape of permanent establishments. This shift has proved challenging from the start, and implementation has not been entirely smooth—for example, not all new or renewed tax treaties follow the new pricing methodology. In this article from Bloomberg BNA’s Transfer Pricing Journal, NERA Affiliated Consultant Dr. Alexander Voegele and Principal Philip de Homont explore this major shift in legislation, the transfer pricing environment, and the ensuing audits and court decisions that could influence various aspects of transfer pricing.