Germany Publishes New Administrative Principles for Transfer Pricing

The German Ministry of Finance has published a BMF letter containing new administrative principles for transfer pricing that updates and replaces several past letters. The new administrative principles apply to all open cases and cover:

• The principles of Income Correction (adjustments) in foreign business relationships between taxpayers and related parties, taking into account the arm's length principle;
• The significance of the OECD Transfer Pricing Guidelines for the examination of the cro…