Advance Pricing Agreements in Germany

Since the first draft guidelines in 2000, the German government has been working on Advance Pricing Agreements (APA) guidance for many years. After the April 2005 Administrative Principles on transfer pricing documentation, on October 5, 2006 Germany’s Federal Ministry of Finance released a long-awaited circular for bilateral and multilateral advance pricing agreements ( “APA circular”). This circular on APAs provides extensive guidance on how taxpayers may apply for, negotiate, and obtain an advance accord in Germany. In addition, an appendix of the “Draft Advance Pricing Agreement” is attached to the APA circular. Enjoying this article? To continue reading you need to take out a FREE trial to the Transfer Pricing Library.




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