Administrative Principles Transfer Pricing 2023 – Structure and Overview of Significant Changes

Abstract

This article provides an overview on the recently published German administrative principles on transfer pricing, looking into the novelties of the current version, which replaces that from 2021. The new principles apply to all years for which audit cases are still open in Germany and also to years that have not been audited. A special focus of the new administrative principles are rules on business restructurings.