Insights Into German Transfer Pricing Regulations

This Weaver: Beyond the Numbers episode explores the evolving landscape of German transfer pricing regulations. Insights from Josh Finfrock, director, Transfer Pricing Services, at Weaver, and Michael Kern from KBHT Germany, discuss critical changes and the implications for companies operating within Germany. As members of Allinial Global, Weaver and KBHT bring extensive knowledge and resources assisting businesses in navigating the complexities of cross-border activities efficiently.

Key Points:

  • Recent changes in German transfer pricing regulations, including the implementation of the DAC7 directive, significantly impact tax audits.
  • The new regulations affect the preparation and filing of transfer pricing documentation, introducing stricter deadlines and broader requirements.
  • These changes influence U.S. companies operating in Germany and further emphasize the importance of proactive planning.

 

 

The episode offers a detailed overview of the modifications to German transfer pricing rules, focusing on the DAC7 directive’s role in promoting tax transparency and modernizing external tax audits. These changes are poised to substantially affect future tax audits, necessitating swift adaptation by companies to avoid potential penalties.

“The preparation and filing obligation, especially the deadline, is reduced to only 30 days,” Kern said. “It can be requested at any time, not only in the course of an audit or an APA procedure, but at any time.” This highlights the urgency for companies to maintain current transfer pricing documentation and reflects the increased scrutiny and accelerated timelines introduced by the new regulations.

Subscribe and listen to future episodes of Weaver: Beyond the Numbers on Apple Podcasts or Spotify.

©2024

Recent Episodes

The CFO seat is being rewritten in real time. Today’s finance leaders are expected to drive growth, lead enterprise-wide systems transformations, and shape AI strategy—while still keeping the close, controls, and capital story airtight. Gartner reports that 59% of finance leaders are already using AI in the finance function, underscoring how rapidly the role is…

Buying behavior has shifted dramatically. Today’s B2B customers do most of their research before ever speaking with a salesperson. In fact, 61% of B2B buyers say they prefer a rep-free buying experience, according to a 2025 Gartner survey. At the same time, U.S. retail e-commerce sales exceeded $1.192 trillion in 2024. Growth still depends…

Dynasties are rare. Most teams rise, win for a season, and fade. A superstar retires. A coach leaves. The chemistry shifts. What once felt inevitable suddenly looks fragile. Sustained excellence is far harder than a single championship run — it requires standards that survive ego, systems that outlast individuals, and a culture strong enough to…