Germany published an updated version of the Ordinance on the application of the arm's length principle according to § 1 paragraph 1 of the Foreign Tax Act in cases of cross-border transfers of functions (Funktionsverlagerungsverordnung – FVerlV) in the Official Gazette on 25 October 2022. The update takes into account amendments introduced by the Withholding Tax Relief Modernization Law of June 2021, which included, among other things, the adaption of the regulations on the arm's length principle in line with current OECD transfer pricing guidelines. In this context, the provisions on the transfer of functions were specified and transferred to...