Germany publishes new draft legislation on Transfer Pricing Documentation

Global Tax Update: April 2017 / Germany

The German Federal Ministry of Finance recently published a discussion paper on the amendment of the Decree on the type, content and extent of the transfer pricing documentation (“DRAFT TP Documentation Decree”, German abbreviation “GAufzV”). (Global Tax Update : April 2017/Germany)

The TP Documentation Decree provides details on what needs to be part of the transfer pricing documentation report and is as decree-law binding for taxpayers and tax authorities. The revised TP Documentation Decree – if it becomes effective in the proposed form – applies to all tax assessment periods from 2017 onwards. The changes in the TP Documentation Decree are motivated by the desire of the German government to implement BEPS action point 13/ OCED Transfer Pricing Guidelines Chapter V (“OECD Guidance”).

This newsletter explains the following topics:

(1) Background
(2) Overview
(3) Outlook

>> Click for Japanese [ドイツ政府による、移転価格文書に係る新たな法案の公表]

(145KB, PDF)

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