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German Ministry of Finance Publishes Fact Sheet Explaining Application of Transaction Matrix Requirement for Transfer Pricing

09 April 2025

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Approved Changes

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Germany

The German Ministry of Finance has published a fact sheet on the application of the new transaction matrix requirements for transfer pricing purposes. As previously reported, the Fourth Bureaucracy Relief Act, published in October 2024, introduced new transfer pricing documentation requirements, including an overview of business transactions referred to as the transaction matrix. The fact sheet lists the required components of the transactions matrix, including: The nature and subject matter of the business transactions; The parties involved, specifying service providers and recipients; The volume and pricing of transactions; The contractual basis; The transfer pricing method used; The relevant tax jurisdictions;...