The Transfer Pricing Method

#5 Germany’s Transfer Pricing Shift: Upcoming Global Implications for Transparency and Compliance


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German transfer pricing legislation is evolving fast, and the implications for multinational companies are profound. From administrative principle updates to heightened scrutiny on financial transactions and intangibles, companies operating in Germany need to be more prepared than ever. 
 
In this episode of The Transfer Pricing Method, host Adriaan van der Heijden is joined by: 
 
🔹 Oliver Treidler – CEO & Founder of TP&C 
🔹 Rudolf Sinx – Managing Director at Quantera Global 
 
Together, they unpack Germany’s recent regulatory developments and what they mean in practice for multinationals and their tax teams. 

Key topics discussed: 

  • 0:00 Introduction & Guest Backgrounds 
  • 01:18: How do the new changes influence day-to-day transfer pricing in Germany? 
  • 03:56: Are similar developments happening across other European countries? 
  • 07:32: What are the main focus points on financial transactions in Germany? 
  • 15:42: Group vs. Standalone Ratings: what if countries disagree? 
  • 18:23: What has changed in intermediary financing structures in the Netherlands? 
  • 20:10: What are the key developments and challenges around intangibles? 
  • 21:47: How are German tax authorities applying the DEMPE framework? 
  • 27:23: What are the developments in tax audits and court cases 
  • 30:13: Summary and Closing Remarks 

 

This episode is packed with real-world lessons, practical tips, and strategic insight to help you mitigate risks and maintain control. 

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