Principles of Transfer Pricing Administration 2023

The Federal Ministry of Finance (BMF) has published the principles of transfer pricing administration in a letter dated June 6, 2023.

BMF letter dated June 6, 2023 – IV B 5 – S 1341/19/10017:003, document 2023/0537819

According to the BMF letter dated June 6, 2023, the “Principles of Transfer Pricing Administration” are being published. The background for this is, among other things, the review of whether the income derived from a taxpayer’s business relationships with related parties abroad has been determined in accordance with the arm’s length principle, or if there is a reason for adjusting the income in accordance with § 1 AStG. The BMF letter extensively addresses the overall issue, particularly with regard to the following key points:

Principles of income adjustment Importance of the OECD Transfer Pricing Guidelines for the examination of cross-border business relationships Guidelines Other general principles.