On 16 December 2022, Germany passed the DAC7 to modernize tax procedural law. The new law amended Section 90 of the General Tax Code (GTC) and tightened the rules on transfer pricing documentation by allowing tax authorities to request transfer pricing documentation at any time and requiring taxpayers to submit the required transfer pricing documentation without a specific request from the tax authorities during an external audit. Previously, the deadline for submitting transfer pricing documentation was 60 days for ordinary transactions (30 days for extraordinary transactions) from the date of the request. With the new regulations, the period for both ordinary and extraordinary business transactions has been reduced to 30 days from the date of the request or the notification of the external audit. The new rules generally apply to tax periods commencing after 31 December 2024.
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