German Ministry of Finance issues new Administrative Principles regarding examination of income allocation between internationally associated enterprises
Executive summary
Germany has had administrative principles in place since 2005 that, among other things, provide guidance regarding the obligations of taxpayers when undergoing a transfer pricing examination (See, Administrative Principles Procedures, BMF letter of 12 April 2005 or AP 2005). On 3 December 2020, the German Ministry of Finance (BMF) updated the AP 2005 by issuing…
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