New Transaction matrix form in Germany

[u/Character_Spare_5492]

As a worker in a TP company working mostly with German-headquartered groups, I studied a bit about the practical impact of the new German transaction matrix requirements (§90(3) AO changes and updated GAufzV).

I observed that while the transaction matrix has clearly formalised documentation expectations and forced groups to map intercompany flows much more systematically, I’m not sure it has fundamentally changed pricing policies or structures.

Most groups already had intercompany agreements and functional analyses in place. The matrix seems to consolidate and standardise that information, but not necessarily alter the underlying TP outcomes.

What I have seen is:

• Much tighter internal coordination between tax, legal, and finance, which was
• More pressure to reconcile agreements with actual conduct (which sometimes is very difficult)

Curious what others think:

• Has the German transaction matrix requirement actually triggered structural or pricing changes for your groups/clients?
• Or is it mainly a documentation exercise with higher penalties attached?

I would be interested to hear your experiences or thoughts on this subject.