German TP-Legislation updated as of June 2021

German legislation on transfer pricing has been updated to align the rules with the OECD Transfer Pricing Guidelines 2017.
The new amendments are effective as of fiscal year 2022.

The update includes revised content on

  • Substance over form
  • Risk analysis
  • Best method rule
  • Use of interquartile range
  • Aggregation of transactions
  • Determination of actual ownership vs legal ownership
  • DEMPE functions
  • Valuation of Hard to value intangibles

Click here for unofficial English translation

4-Verkuendetes-Gesetz