Germany transfer pricing documentation checklist
March 08, 2010
Stephan Schnorberger and Juliane Rosenkranz of Baker & McKenzie outline the German transfer pricing documentation requirements and strict penalty regime.
The German legislature has introduced a statutory obligation to document transfer prices and the arm’s length nature of those for tax years beginning 2003 in section 90 subsection 3 of the General Tax Act (GTA). The statute provides that taxpayers are required to maintain documentation regarding cross-border transactions with related parties. The documentation obligation also covers headquarter-permanent establishment dealings (see Schnorberger, World Finance Sept./Oct. 2005, p.48-50).
Sorry. You must be a subscriber to view this article. Alternatively, why not take a free trial? To subscribe and access this article immediately simply click here or call +44(0)207 779 8380.