Insights Into German Transfer Pricing Regulations

March 11, 2024

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.

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