New German Administrative Principles on Transfer Pricing (BMF-AO-2023)

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6 June 2023 Germany published it’s new updated administrative principles on transfer pricing.

The new publication includes expanded guidance on transfers of functions (and valuation – see English translation) and financial transactions. With regard to the latter, reference is made to two recent decisions of the Federal Fiscal Court (BFH) on intra-group loans (BFH of 18 May 2021, I R 4/17, and of 13 January 2022, I R 15/21).

With the exception of the new content on transfer of functions, the new principles can be applied retroactively by the tax authorities.

Click here for an unofficial English translation of the German 2023 Administrative Principles on Transfer Pricing


BMF AO 2023-vom-06062023 ORG

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