During the webinar, our Kroll experts Kerim Keser, Managing Director of Transfer Pricing; Kroll Director Moritz Neumann; and Vice President Su Bali discuss the new regulations and their effects on economic analyses for transfer pricing for intercompany financing.
On March 22, 2024, Germany passed the Growth Opportunities Act, which includes new regulations for intercompany financing transactions. The act’s main implications relate to the ability to service debt obligations and the arm’s length nature of the interest rates on inbound loans, as well as the routine nature of group financing activities. These rules apply retroactively as of 2024 and are applicable to both new and existing financing transactions.
On August 14, Germany published a draft update to the Administrative Principles Transfer Pricing, incorporating the new rules for intercompany financing transactions, and invited the public to comment on the draft until September 6. The draft Administrative Principles provide additional clarifications on how tax authorities will apply the new rules.
Learn more about intercompany loans, financing activities, and other implications of the new rules, and how Kroll can help you with these changes.
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