6 June 2023 Germany published it’s new updated administrative principles on transfer pricing.
The new publication includes expanded guidance on transfers of functions (and valuation – see English translation) and financial transactions. With regard to the latter, reference is made to two recent decisions of the Federal Fiscal Court (BFH) on intra-group loans (BFH of 18 May 2021, I R 4/17, and of 13 January 2022, I R 15/21).
With the exception of the new content on transfer of functions, the new principles can be applied retroactively by the tax authorities.