Executive summaryOn 14 July 2021, the German Ministry of Finance (MoF) issued the Administrative Principles Transfer Pricing (AP TP). Administrative principles in Germany represent a third element (in addition to the tax law and executive orders) of German tax provisions. Although not binding for taxpayers and courts, administrative principles serve as additional guidance for the interpretation and illustration of the tax law and executive order; accordingly, they are of significant practical importance for taxpayers. Publication of the AP TP follows recent legislative changes to Germany’s transfer pricing (TP) framework effective for fiscal years starting 1 January 2022.The objective of the...