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Ex­ter­nal Tax Re­la­tions

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Source:  Fotolia.de, Foto: Milton Oswald

General Information

The documents on this website provide information about German legislation relating to external tax relations, especially transfer pricing. For a comprehensive overview of the German tax system, please refer to the Finance Ministry brochure An ABC of Taxes.

Please note that this is not an exhaustive list. These working translations are provided as a courtesy by the Federal Ministry of Finance’s Language Service and are merely for informational purposes. Only the German-language versions are authoritative for the application of the law. Please note that the translations have not been coordinated with other government bodies in Germany.

The most recent English translation of the German Fiscal Code (Abgabenordnung) is available here [PDF, 1MB] .

The most recent English translation of the External Tax Relations Act (Außensteuergesetz) is available here [PDF, 187KB] .

You can find ordinances related to the External Tax Relations Act here:

You can find the Finance Ministry circulars related to the above ordinances here:

The Verrechnungspreise glossary provides an overview of the German terminology related to transfer pricing [PDF, 1MB] (only available in German).

You can find selected sections of the External Tax Relations Act here:

The ordinances related to transfer pricing are available here:

The Finance Ministry circulars related to transfer pricing are available here:

Selected sections of the German Fiscal Code (Abgabenordnung) related to transfer pricing are available here:

  1. Section 90 of the Fiscal Code - Obli­ga­tion of par­tic­i­pants to co­op­er­ate [PDF, 31KB]
  2. Section 138 of the Fiscal Code - Re­port­ing gain­ful oc­cu­pa­tion [PDF, 27KB]
  3. Section 138a of the Fiscal Code - Coun­try-by-coun­try re­ports by multi­na­tion­al en­ter­prise groups [PDF, 35KB]
  4. Section 162 of the Fiscal Code - Es­ti­mat­ing tax bases [PDF, 30KB]
  5. Section 379 of the Fiscal Code - Gen­er­al mi­nor tax fraud [PDF, 29KB]

Relevant European Court of Justice judgments are available here:

Further information about transfer pricing is available here:

The Finance Ministry circulars related to MAP/APA are available here:

Further information about MAP/APA is available here:

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