The German Ministry of Finance (BMF) has published Administrative principles 2020 (Verwaltungsgrundsätze 2020), which contains updated guidance on audits/examinations of transfer pricing between related parties and the duty of taxpayers to cooperate as per Section 90 of the General Tax Code (GTC), as well as the estimation of taxable income and surcharges as per Section 162 of the GTC.
One of the key areas covered in Administrative Principles 2020 is the transfer pricing documentation requi…