The German Ministry of Finance issued new Administrative Guidelines called Verwaltungsgrundsätze 2020 in December 2020. The guidelines tend to have strong practical implications because they are considered binding on the tax authorities. German tax authorities may have to make reassessments to stay in line with the new guidelines, which will apply to German taxpayers in transfer pricing cases.

In “Transfer Pricing for the Individual Practitioner,” in Bloomberg’s Winter 2020/Spring 2021 Transfer Pricing Forum, NERA Director Philip de Homont and Dr. Georg Dettmann discuss the new legislation and regulations that will affect the transfer pricing landscape in Germany. As well as providing an overview on what we can expect from tax authorities and considering the new Administrative Guidelines, the authors provide an insight on the following topics:

• Legislation;
• Cases and rulings;
• Transfer pricing documentation;
• Transfer pricing examinations/audits; and
• The effect of COVID-19 on the German tax landscape.