In depth · Group
Transfer pricing: the transaction matrix in 30 days.
Since 1 January 2025 the transaction matrix, the master file and the records on extraordinary transactions are due without any separate request — the clock starts when the audit order is served.
The audit order is the starting gun, not the request.
Until 2024 the audit team asked for the transfer pricing documentation, and only then did the clock start. Since 1 January 2025 that is no longer so: three sets of records have to be produced without any separate request, within 30 days of the audit order being served (§ 90 Abs. 4 Satz 3 AO).
What has to be produced has changed too. The transaction matrix — a structured, tabular overview of the cross-border transactions with related parties and permanent establishments — has been a record-keeping requirement in its own right since the Fourth Bureaucracy Relief Act.
The name understates the work. Anyone not already maintaining the matrix will not assemble it from accounting data in 30 days — all the less so where the audit order also covers years before 2025. That is precisely when the tax authorities require it for those periods as well.
Where it is missing, a surcharge of 5,000 euros has to be imposed (§ 162 Abs. 4 Satz 1 AO). That is the smaller part of the problem: without usable records the rebuttable presumption of understated income applies, and the range of estimation may be exhausted to the taxpayer’s disadvantage.
The essentials at a glance
- 30 days, unpromptedThe period runs from service of the audit order. There is no longer a letter that triggers it.
- Three sets of records, not all of themWhat is due is the transaction matrix, the master file and the records on extraordinary transactions.
- 5,000 euro surchargeWhere the transaction matrix is missing, the surcharge has to be imposed. Late production adds at least 100 euros a day.
What falls due by itself — and what only on request
Unprompted, within 30 days
- The transaction matrix under § 90 Abs. 3 Satz 2 Nr. 1 AO
- The master file, where turnover in the preceding financial year was at least 100 million euros
- The records on extraordinary transactions
Only on request — then also within 30 days
- The documentation of the facts of the individual transactions
- The arm's length documentation with the economic and legal basis of the pricing
- The tax authorities may call for them at any time, including during the audit
In short: the relief lies in the volume, not in the time — fewer records than before, but due without anyone asking.
How the deadline runs
- 1The audit order arrivesService starts the 30-day period. A separate request from the tax authorities is no longer provided for.
- 2Check the audit periodWhere the order also covers years before 2025, the tax authorities require the transaction matrix for those periods too, following the guidance of 2 April 2025.
- 3ProduceTransaction matrix, master file and extraordinary transactions. In justified individual cases the period may be extended (§ 90 Abs. 4 AO).
- 4Supply what is called forThe facts and arm's length documentation follow on request — again within 30 days each time.
Thresholds and deadlines
| Item | Value | Source |
|---|---|---|
| Production on request | within 30 days | § 90 Abs. 4 Satz 2 AO |
| Production without request in an audit | within 30 days of service of the audit order | § 90 Abs. 4 Satz 3 AO |
| Master file | from 100 million euros of turnover in the preceding financial year | § 90 Abs. 3 AO |
| Extraordinary transactions | to be recorded contemporaneously — within six months of the end of the financial year | § 3 GAufzV |
| Relief for smaller companies | up to 6 million euros of goods supplied and up to 600,000 euros of other services to related parties | § 6 GAufzV |
| Country-by-country report | from 750 million euros of consolidated turnover; filed at the latest one year after the end of the financial year | § 138a AO |
What failures cost
| Situation | Consequence | Source |
|---|---|---|
| Records not produced or unusable — or transaction matrix missing | surcharge of 5,000 euros | § 162 Abs. 4 Satz 1 AO |
| An additional amount of income above 5,000 euros results | at least 5 and at most 10 per cent of that additional amount | § 162 Abs. 4 AO |
| Usable records produced late | at least 100 euros for each full day of delay, up to 1,000,000 euros | § 162 Abs. 4 AO |
| No usable records | rebuttable presumption of understated income; the range of estimation may be exhausted to the taxpayer's disadvantage | § 162 Abs. 3 AO |
| Excusable breach, or one involving only slight fault | a surcharge should not be imposed | § 162 Abs. 4 AO |
Working together
What FRADECO takes on.
- BuildingThe transaction matrix from accounting and contract data, carried forward each year — including retrospectively for audit periods before 2025.
- DocumentingThe facts and arm's length documentation, the master file from the 100 million threshold, and the recording of extraordinary transactions within the six-month period.
- ProducingDeadline monitoring from service of the audit order, an application for an extension in justified cases, and support through the audit.
The pricing is of course your commercial decision. We document it and defend it before the tax authorities — the earlier we see the data, the sounder the documentation becomes.
The clock starts with the audit order. Since 1 January 2025 the transaction matrix, the master file and the records on extraordinary transactions have to be produced within 30 days of its service — without any separate request (§ 90 Abs. 4 Satz 3 AO). Where the order also covers years before 2025, the transaction matrix has to be prepared for those periods too, following the ministry guidance of 2 April 2025.
- Legislation: § 90 AO · § 162 AO · § 138a AO · § 3 GAufzV · § 6 GAufzV
- Ministry guidance on the transaction matrix under § 90 Abs. 3 Satz 2 Nr. 1 AO of 2 April 2025, GZ IV B 3 - S 0225/00019/004/009
- Fourth Bureaucracy Relief Act of 23 October 2024, BGBl. 2024 I Nr. 323 — revised § 90 Abs. 3 and Abs. 4 AO, applicable from 1 January 2025 (Art. 97 § 37 Abs. 5 EGAO)
As at 22 August 2026. This page reflects the law as at that date and does not replace a review of the individual case.
Frequently asked
About the transaction matrix and the 30-day deadline.
What is the transaction matrix?
A structured, tabular overview of the cross-border transactions with related parties and permanent establishments. Since 1 January 2025 it has been a record-keeping requirement in its own right under § 90 Abs. 3 Satz 2 Nr. 1 AO.
The tax authorities set out its components in guidance of 2 April 2025 (GZ IV B 3 - S 0225/00019/004/009) and illustrated them with examples.
We build it from your accounting and contract data and carry it forward each year.
When exactly does the 30-day period start?
On service of the audit order — not on a request for the records. § 90 Abs. 4 Satz 3 AO expressly requires production without any separate request.
Anyone waiting for a letter loses the whole month.
Send us the audit order as soon as it arrives — from then on we take over the deadline monitoring and the production.
Do we have to supply the entire documentation in 30 days?
No. What is due without a request is only the transaction matrix, the master file and the records on extraordinary transactions.
The facts and arm's length documentation can be called for by the tax authorities at any time; a 30-day period then applies again.
Does the transaction matrix apply to years before 2025 as well?
In the view of the tax authorities, yes, in so far as an audit order served in 2025 or later also covers earlier periods.
That is the hardest point in practice: for closed years the data has to be brought together after the event from the accounts and the contracts.
We handle that reconstruction — it is the most demanding part and the reason to start early rather than under a deadline.
From what size do we need a master file?
From turnover of 100 million euros in the preceding financial year, where the company is part of a multinational group (§ 90 Abs. 3 AO).
Below that threshold it remains the transaction matrix and the facts and arm's length documentation. We prepare all three, and the master file once the threshold is reached.
How do we document transfer prices between a foreign parent and the German subsidiary?
The group's documentation helps, but it is not enough. Germany requires the records from the German company, for its own transactions. In practice the work divides up like this:
- The master file describes the group and its transfer pricing system. It usually comes from head office and can be adopted — from 100 million euros of turnover at the German company (§ 90 Abs. 3 AO).
- The facts and arm's length documentation is the German part: which services flow between head office and the German entity, on what terms, by which method, against what comparables. Head office cannot supply this part, because it takes the German perspective.
- The transaction matrix lists precisely those transactions in structured form.
The point at which foreign groups regularly come unstuck is language. Under § 2 Abs. 5 GAufzV the records have as a rule to be prepared in German. The tax authorities may allow a departure on application — the application has to be made before the records are prepared, or at the latest without delay after the authorities have called for them. Any necessary translations of contracts and similar documents form part of the records.
A master file in English is therefore not automatically sufficient. Anyone making the application only once the audit has begun has to deal with it on top of the 30-day deadline.
We make the language application, adopt the group's master file and prepare the German part — in German, agreed with your head office.
Is there any relief for smaller companies?
Yes. Under § 6 GAufzV the record-keeping duties count as met where the amounts for goods supplied to related parties do not exceed 6 million euros and the fees for other services do not exceed 600,000 euros in the financial year.
Duties to give information and to produce documents are unaffected — and affiliated companies are aggregated for the calculation. We check each year whether you are still within the limits, since exceeding them takes effect from the following year.
What does it cost if we miss the deadline?
Where records are not produced or are unusable, and where the transaction matrix is missing, a surcharge of 5,000 euros has to be imposed (§ 162 Abs. 4 Satz 1 AO). If an additional amount of income above 5,000 euros results, the surcharge is at least 5 and at most 10 per cent of it.
Where usable records are produced late, it is at least 100 euros for each full day of delay, up to 1,000,000 euros. Where the breach is excusable or involves only slight fault, a surcharge should not be imposed.
Where the deadline cannot be met, we apply for an extension — in justified individual cases it can be extended (§ 90 Abs. 4 AO).
What counts as an extraordinary transaction?
§ 3 GAufzV names in particular the conclusion and amendment of long-term contracts with a material effect on income, transfers of assets in the course of restructurings, transfers of assets on material changes of functions and risks, transactions connected with a material change of business strategy, and the conclusion of cost-sharing agreements.
These records have to be prepared contemporaneously, that is, within six months of the end of the financial year. Tell us as soon as such a transaction is coming up — the six-month period runs independently of any audit.
Where do we find the ongoing changes on this subject?
Dated commentary is under News, where new legislation and ministry circulars are put in context as they come.
The running work — transaction matrix, documentation and support through the audit — is described under Advisory & Cross-border.
Goes with this
Where the figures come from — and who defends them before the audit.
Before the audit order arrives
Either the matrix exists, or it has to be built in 30 days.
We build the transaction matrix from your accounting and contract data, carry it forward each year and add the master file and the facts and arm's length documentation — including retrospectively for audit periods before 2025.
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