The changes to transfer pricing documentation introduced by the Fourth Bureaucracy Relief Act have applied since 2025 — but their full practical significance shows above all in current documentation and in tax audits from 2026. Companies should therefore adjust their processes early.
What continues to apply
As before, transfer pricing documentation has to be prepared for business relationships with related parties. It still comprises:
- a description of the transactions (documentation of the facts)
- and the derivation of arm’s length transfer prices (documentation of appropriateness)
New: the transaction matrix
New is the mandatory transaction matrix, in which all transactions have to be presented in a structured form — whether they are ordinary or extraordinary.
The deadline cut to 30 days
The deadline for producing the documentation has been cut uniformly to 30 days. That applies both:
- where the tax authorities ask for it expressly
- and in the course of a tax audit
An extension is possible only in individual cases and on a reasoned application. In practice that means the documentation has to be available considerably sooner and in full.
What has to be produced without being asked
In a tax audit certain records have to be submitted proactively, without any separate request:
- documentation of extraordinary transactions
- where applicable the master file (for larger groups)
Beyond that, the complete transfer pricing documentation can be requested separately at any time.
Wider powers for the tax authorities
The tax authorities can now request the documentation at any stage of the proceedings. They can also require improvements where in their view the records are incomplete. That increases the pressure on companies to keep their records ready for inspection at all times.
Where documentation is missing or inadequate, the transfer prices may be estimated.
Outlook: digital interfaces
The requirements as to the quality and completeness of the documentation are therefore rising noticeably. A further step concerns the planned introduction of uniform digital interfaces for tax-relevant data.
The aim is to make it easier for the tax authorities to analyse company data and to make audits more efficient. The relevant regulation is still awaited; it is expected to come into force at the earliest at the end of 2028.