The German Federal Ministry of Finance has published its position on transfer pricing principles (specifically the correction of income pursuant to section 1 of the External Tax Relations Act - the income adjustment clause) in its latest administrative principles regarding transfer pricing.
The 2021 Administrative Principles (which are binding on the tax authorities, but
not on the taxpayer) cover 44 pages, and replace a number of previously published
administrative principles on transfer pricing matters, including those of 1983 and
This PwC Newsalert provides key points for the real estate sector.