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7. Germany

Germany

<Monetary threshold for LF preparation>

​ Applicable if related-party transactions exceed any of the following thresholds:

  • EUR 6 million for tangible (inventory) transactions

  • EUR 600,000 for non-inventory (e.g., services, royalties) transactions

<Preparation deadline>

  • Thers is no explicit statutory deadline. However, contemporaneous documentations must be prepared for extraordinary business transactions within 6 months after the end of the fiscal year.

<Submission deadline>

  • Within 30 days of a request by the tax authority.

<Language>

  • German is required, but English may also be accepted.

<Penalty>

  • A penalty ranging from 5% to 10% of the additional income from a correction may be imposed, with a minimum of EUR 5,000.

  • Failure to submit LF on time may result in a penalty of up to EUR 1,000,000, with a minimum of EUR 100 per full day of delay.

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