Changes in the submission of transfer pricing documentation

In a press release dated 26 March 2025, the Federal Constitutional Court (BVerfG) announced its decision to reject a constitutional complaint against the Solidarity Surcharge Tax Act of 1995 (SolZG 1995).

According to the German Federal Fiscal Court, a pure holding company in the form of a partnership can only deduct 60 % of its general administration costs for tax purposes.

According to the requirements of the Corporate Sustainability Reporting Directive (CSRD for short), companies will in the future be required to report in detail on how they deal with social and environmental challenges together with their annual financial statements. To this end, on 24 July 2024, the German Federal Cabinet passed a draft law to implement the Corporate Sustainability Reporting Directive (EU Directive 2022/2464), or CSRD Implementation Act for short, after the German Federal Ministry of Justice published a corresponding draft bill on 22 March 2024.

On 15 March 2024, a sufficient majority of EU member states in the Committee of Permanent Representatives, a subsidiary body of the Council of the European Union, agreed to the diluted draft of the Corporate Sustainability Due Diligence Directive (CSDDD). Germany abstained from the vote. The draft now adopted deviates from the preliminary political agreement originally reached in the trilogue. It must now be formally adopted by the EU Council and subsequently approved by the EU Parliament.

On 22 March 2024, the German Federal Council approved the Mediation Committee's compromise proposal on the Growth Opportunities Act. As a replacement for the originally in Germany planned interest rate cap, which was removed from the draft bill, new regulations for cross-border financial transactions and services will therefore be introduced from the 2024 tax period (Section 1 (3d) and (3e) Foreign Transactions Tax Act (AStG)).