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Since 1 January 2025, new submission requirements have applied to transfer pricing documentation, in particular with respect to the transaction matrix. The objective was to support a more risk‑based and efficient tax audit process. In practice, however, the local file is often requested almost simultaneously, while the statutory submission deadline remains limited to 30 days. One year after the introduction of the transaction matrix, we take stock of practical experience and outline considerations on how companies can meet deadlines, mitigate surcharge risks and organise evidence retention.

A new report from the OECD provides fixed margin ranges for limited risk distribution and commissionaire activities. The report forms an annex to the OECD Guidelines but it is currently unclear if Germany will apply the rules.