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TAX NEWS - January 2010

Germany Tax: Transfer Pricing Documentation

Extraordinary transactions must be documented on a contemporaneous basis under Germany's transfer pricing documentation requirements to avoid potentially severe tax consequences and penalties. Documentation is considered contemporaneous if it is prepared within six months after the end of the financial year in which the relevant business transaction took place. Therefore, calendar year taxpayers that carried out extraordinary transactions in financial year 2009 need to prepare the transfer pricing documentation by 30 June 2021 to meet the contemporaneous documentation requirements.
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