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New transfer pricing rules - Draft ATAD Implementation Act

19 December 2019

In the area of transfer pricing, there has been a kind of tradition to give Christmas gifts to taxpayers since 1999. In order to stick to that tradition, the German Ministry of Finance (“BMF”) published a draft law regarding the implementation of the Anti-Tax Avoidance Directive (“ATAD draft ATAD draft bill”) on 10 December 2019. What at first glance seemed to be a simple implementation of the corresponding EU directive turned out to be a comprehensive collection of ‘Christmas gifts’ for the world of transfer pricing.

Further information can be found in the transfer price update enclosed.