First announced: Administrative guidance published in April 2025; the Transaction Matrix requirement is mandatory from Jan 1, 2025 (guidance and detailed rules published April 2025).
Submitted by: NYBACS Compliance Desk
Germany now requires a Transfer-Pricing “Transaction Matrix” as part of TP documentation; authorities expect submission within 30 days of an audit notice.
Guidance and administrative rules were published in April 2025.
Multinationals should prepare a transaction matrix and be audit-ready immediately.
What changed: Germany formalised an enhanced TP documentation regime requiring a concise Transaction Matrix describing intercompany payments and their economic rationale; taxpayers must prepare the matrix and, where an audit notice is received, submit it (often automatically) within 30 days. Administrative guidance and commentary were issued in April 2025 and the documentation obligations are treated as mandatory for audits in 2025 onward.
Who’s affected: Multinationals operating in Germany or with German addressable profit streams; companies with intercompany financing, service recharges, royalty flows, or cost-sharing arrangements are particularly exposed.
Immediate actions (NYBACS checklist):
- Build a transaction matrix (rows = intercompany counterparties; columns = type/value, contractual basis, transfer pricing method, key comparables).
- Reconcile intercompany ledgers to the matrix and ensure supporting invoices/agreements are available.
- Prepare to deliver TP documents rapidly on audit — consider pre-packaging a compliant submission.
Practical notes: The 30-day rule shortens response time in audits; produce a template and run a dry-run audit to ensure you can assemble required data quickly. Seek local counsel for any ambiguous items before submission.
