New documentation requirements for transfer pricing were introduced in Germany with legislation on the implementation of the amendments to the EU administrative assistance directive and further measures against base erosion and profit shifting (Anti-BEPS-I law). The law provides for a three-tiered approach to transfer pricing documentation:
The federal ministry of finance (BMF) recently published a discussion draft for amending the rules currently in effect, and to take into account the changed legal situation due to the newly introduced Anti-BEPS-I law. The structure of the transfer pricing documentation is to be adapted so that a differentiation is made between Local file and Master file.
The revised measures would be applicable for assessment periods 2017 onwards. The effective provisions would simultaneously repeal the previous ordinance.
The discussion draft contains three material changes:
Read an April 2017 report [PDF 322 KB] prepared by the KPMG member firm in Germany
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