Starting January 1, 2025, taxpayers in Germany must include a Transaction Matrix in their transfer pricing documentation under Sec. 90 (3) AO, as introduced by the Fourth Bureaucracy Relief Act.
On April 2, 2025, the German Federal Ministry of Finance (BMF) published an official information sheet clarifying key aspects of the Transaction Matrix.
📌 What is the Transaction Matrix?
It’s a structured, tabular overview providing tax authorities with key details on cross-border business transactions with related parties and permanent establishments.
Tighter Deadlines & Penalties
– Tax authorities can now demand submission at any time.
– Deadline for submission: 30 days (extensions only in exceptional cases).
If a tax audit is announced, records must be provided within 30 days of the audit notice—even if issued before January 1, 2025.
Non-compliance? A penalty surcharge of EUR 5,000 applies.
📂 What Comes Next?
Following the Transaction Matrix submission, tax authorities will likely request the local file within another 30 days, using the matrix to focus on high-risk transactions.
Please see below a summary of the matrix outline examples shared by the tax authority and the level of detail requested.
Now is the time to ensure transfer pricing documentation is audit-ready. Let’s discuss—are you prepared?
For more information, please contact Daniel.medvedovsky@basefirma.com