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.

Thought Leadership

German Tax Update – 10 July 2025

July 16, 2025

In this week’s German Tax update, we discuss the following: Disposal Gains in Tiered Partnerships: BFH Provides First Clear Guidance on Trade Tax Treatment, and CJEU Confirms: Denial of VAT Deduction and Joint and Several Liability in Cases of VAT Fraud Are Compatible.

Thought Leadership

Exploring Indirect Transfer Rules in APAC region: Effects of the Hong Kong Inward Re-Domiciliation Regime

July 14, 2025

Learn the Indirect Transfer Rules in key APAC jurisdictions and the potential tax implications of re-domiciling a nonresident company to Hong Kong.

Thought Leadership

US Tax Reform 2025: What Consequences Does the OBBBA Have for German Companies With US Operations?

July 14, 2025

With the ‘One Big Beautiful Bill Act’ (OBBBA), the US Congress is passing far-reaching tax changes. There is also an acute need for action for companies based in Germany with US subsidiaries, permanent establishments or IP structures.

Thought Leadership

Singapore Tax Alert: Financial Sector Incentive (FSI) – New Fund Management (FM) Listing, Singapore Equities and Basic Tier (BT) Schemes

July 13, 2025

The Monetary Authority of Singapore (MAS) has provided further information regarding the new financial sector incentives (“FSI”) announced during 2025 Budget Statement in the MAS Circular released on 3 July 2025.

Featured Experts