Germany: New Transfer Pricing Rules May Limit Interest Deduction in Inbound Cases

The Growth Opportunities Act (Wachstumschancengesetz), effective from March 28, 2024, introduced major revisions to Germany’s transfer pricing regulations for intercompany financing.

These new regulations are designed to prevent profit shifting via improper financing setups by enhancing the enforcement of the arm’s length principle in international financing deals.

This article delves into the challenges and necessary actions for cross-border transactions from the 2024 tax assessment period onward, following the Growth Opportunities Act:

Limiting the interest deduction in German inbound cases
Impact of the classification of routine financial services
Work approaches to ensure compliance for multinational groups

Read and download the full article here.

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