New developments regarding transfer pricing documentation in Germany

In 2003, Germany enacted legislation that established extensive cooperation and documentation requirements and provided heavier possible sanctions for violations of the requirements. This legislation was the reaction to the landmark decision of the Federal Tax Court in 2001, which struck down increased documentation requirements for transactions between members of multinational companies. This article discusses the current requirements regarding transfer pricing documentation in Germany and the steps that should be taken when setting up a documentation management system to ensure compliance with the requirements.