The German Ministry of Finance has published draft revisions to the Administrative Principles for Transfer Pricing to account for changes regarding interest deductions that were introduced by the Act to Strengthen Growth Opportunities, Investment, and Innovation as well as Tax Simplification and Tax Fairness (Growth Opportunities Act), which was published in the Official Gazette on 27 March 2024. As previously reported, the Act introduced new interest deduction limitation rules providing that the deduction of interest on cross-border intercompany financing is subject to three tests from the 2024 fiscal year, including the debt capacity/cash-flow test, the business purpose test, and the...