Webinar–Germany Introduces New Regulations for Intercompany Financing

On March 22, 2024, Germany passed the Growth Opportunities Act, which includes new regulations for intercompany financing transactions. The main implications relate to the ability to service debt obligations and the arm’s length nature of the interest rates on inbound loans, as well as the routine nature of group financing activities. These rules apply retrospectively as of 2024 and are applicable for both new and existing financing transactions.

Additionally, on August 14, 2024, Germany published the draft to update the Administrative Principles Transfer Pricing incorporating the new rules for intercompany financing transactions and invited the public to comment on the draft until September 6, 2024. The draft Administrative Principles provide additional clarifications on how tax authorities will apply the new rules.

Learn more about intercompany loans, financing activities, implications and how we, as Kroll, can help you with these changes.

Our agenda topics for the webcast will be:

• The German Growth Opportunities Act, the draft Administrative Principles Transfer Pricing and Intercompany Financing
• Summary of the draft Administrative Principles Transfer Pricing
• Discussion of the implications for existing and new intercompany financing arrangements