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On 12 June 2026 the Bundesrat, the upper house of parliament, agreed to a simplification of the notification requirement for real estate transfer tax (RETT) for share deals. This legislative initiative had been triggered by a ruling from the Federal Fiscal Court (BFH dated 27/10/2025, II B 47/25), in which the court expressed serious doubts about the authorities’ current practice. According to this practice, for a share deal separate RETT notifications had to be submitted both on signing and on closing – a structure that caused a risk of double taxation and considerable uncertainty in practice.

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.

Operators of digital platforms must submit their report of traders on their platform to the Federal Central Tax Office (BZSt) by 31 January 2025. Find out what you need to do in this article.

Stricter requirements for the recognition of expenses from cross-border financing relationships: The Annual Tax Act 2024 disappoints hopes for a true grandfathering protection for existing loans. This article explains what companies now need to bear in mind.

The legislator has amended the transfer pricing documentation obligations, which were tightened at the end of 2022, and brought forward their application significantly. The following article explains what companies should now bear in mind.

Two changes to the German Foreign Tax Act (Außensteuergesetz – AStG) will affect the treatment of intercompany cross-border financing transactions for tax periods from 2024. This post summarizes the new rules.

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.