Germany: Draft amendments to transfer pricing documentation ordinance

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The Ministry of Finance on 23 February 2017 published draft amendments to the transfer pricing documentation ordinance. These show the changes introduced by the bill on the implementation of amendments to the EU Mutual Assistance Directive and other measures against base erosion and profit shifting (BEPS) including the introduction of country-by-country reporting. Other requirements include:

The draft bill also includes the following requirements:

  • Naming the person involved in decisions regarding intercompany transactions;
  • Presenting available information at the time the transfer price was determined; and
  • Providing tax auditors with access to the benchmarking database.

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