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Germany publishes administrative guidance on Transaction Matrix

10 April 2025

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Tax Alerts, National/Federal Taxation, T...

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Germany

Following recent legislative changes to the German transfer pricing (TP) documentation scope and filing requirements, the German tax authorities, on 2 April 2025, issued administrative guidance on the additional requirement to prepare a "Transaction Matrix."Taxpayers are required to (automatically) submit the Transaction Matrix within 30 days upon receipt of a tax audit order.Taxpayers should be aware that the Transaction Matrix requirement also applies for previous years, if a tax audit order issued in 2025 is subject to examination periods prior to 2025.Companies should understand the timing, scope and extent of the changed rules and evaluate the significance of changes to...