Expected developments in German transfer pricing

December 10 2011

After almost a decade of intense developments and numerous new regulations, ordinances and administrative principles on transfer pricing in Germany (including the widely commented on introduction of the rules on transfers of business functions), 2011 has been a quiet year. This should not, however, lead to the conclusion that the German Ministry of Finance has shifted its focus away from transfer pricing matters or is taking time to reflect on the comprehensive rules introduced so far before deciding what steps to take next. Lorenz Bernhardt and Michael Jakob of PwC run-through the anticipated tax developments in German transfer pricing.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

more across site & shared bottom lb ros

More from across our site

Direct Tax

Washington DC Capitol view on cloudy sky background

Ex-US Supreme Court advocate convicted on 12 counts in tax trial

Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff

Sam Sholli, February 26 2026

Transfer Pricing

Suited figure pointing to audit among various hexagonal icons

TP documentation in a fragmented world: how to limit audit triggers

Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions

Daniel Moalusi, February 26 2026

Direct Tax

‘Tax at breaking point’: Thomson Reuters’ AI tech hits one million users

The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR

Sam Sholli, February 24 2026

Direct Tax

Deloitte unveils €20bn EMEA combination

The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth

Tom Baker, February 24 2026

Indirect Tax

The IBS and why it changes everything in Brazil’s consumption tax system

Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty

Wesley Fragas, February 24 2026

Direct Tax

A&M Tax launches dedicated pillar two, TP team in Saudi Arabia

The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering

Tom Baker, February 23 2026

Direct Tax

India and France sign updated tax treaty in ‘significant development’

The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits

Sam Sholli, February 23 2026

Indirect Tax

‘Refunds likely to be a mess’: US Supreme Court strikes down Trump’s tariffs

The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled

Sam Sholli, February 20 2026

Direct Tax

Aerial view of Christ and Botafogo Bay from high angle.

A taxing week: Despite major tax reform, Brazil’s hiring slowdown should come as no surprise

While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment

Sam Sholli, February 20 2026

Direct Tax

This week in tax: BDO UK and BDO Ireland rubber-stamp $1.5bn merger

The expanded firm will comprise roughly 8,500 employees, including 550 partners; in other news, Paul Hastings and Macfarlanes made senior tax hires

Sam Sholli, February 20 2026