Germany’s New Transaction Matrix for Transfer Pricing Audits: How Reptune Makes Compliance Effortless

On 2 April 2025, the German Ministry of Finance published administrative guidance on the Transaction Matrix, introduced under the Fourth Act to Reduce Bureaucratic Burdens for Citizens, Businesses, and the Administration (the so-called Fourth Bureaucracy Relief Act).

Under the updated transfer pricing documentation requirements, taxpayers must, within 30 days, provide a Transaction Matrix with detailed information regarding their cross-border intercompany transactions during the financial years for which the tax authorities have announced a tax audit.

The Transaction Matrix can be requested for any open financial year. Failure to provide the matrix triggers a EUR 5,000 penalty.

As frameworks like the OECD’s Base Erosion and Profit Shifting (BEPS) evolve and the emphasis on economic co-operation grows, Germany’s new documentation requirement highlights the need for companies to structure, monitor, and manage their transfer pricing risk assessment carefully.

The German Transaction Matrix in More Detail

The Transaction Matrix provides the German tax authorities with a standardized view of a taxpayer’s controlled cross-border transactions, enabling them to quickly target specific intercompany transactions for audit review.

This development reflects a wider global movement toward structured, transparent reporting under stricter transfer pricing regulations, affecting multinational enterprises and multinational corporations worldwide.

What Must Be Included in the Transaction Matrix?

Each controlled transaction must specify:

1. Transaction Type (e.g., delivery of goods, provision of services, licensing of intellectual property)
2. Parties Involved (service provider and service recipient)
3. Transaction Volume and Consideration (in euros)
4. The Contractual Basis (reference to contractual documentation)
5. Transfer Pricing Method Applied (such as Cost-Plus Method or Comparable Uncontrolled Price Method)
6. The Involved Tax Jurisdictions
7. Non-Standard Taxation (e.g., preferential regimes such as IP boxes)

This aligns with the OECD’s principles under Operation and Development OECD initiatives and reinforces the importance of accurately capturing functions, assets, and risks when preparing transfer pricing documentation.

What Format Does the German Transaction Matrix Need to Have?

The German Ministry of Finance published two example Transaction Matrices.

In principle, these examples must be followed closely. Any deviations must be discussed and agreed upon with the tax authorities in advance.

The Transaction Matrix generated by Reptune is fully aligned with the guidance provided by the German Ministry of Finance, helping businesses seamlessly meet Germany’s evolving documentation requirements.

How Reptune Simplifies the Preparation of the German Transaction Matrix

Without automation, compiling the Transaction Matrix would be a tedious and time-consuming task, requiring extensive data gathering across departments and manual formatting—thereby increasing the risk of errors during the transfer pricing documentation process.

Reptune addresses this challenge through an efficient transfer pricing risk solution by offering:

✅ One-Click Transaction Matrix Generation

All data stored in Reptune—subject matter, transfer pricing methods, jurisdictions, contracts, and parties—automatically feeds into a ready-to-download, audit-ready matrix.

✅ Coverage of Historical and Current Data

The feature applies to all existing intercompany transactions captured in Reptune, ensuring comprehensive coverage across both historical and future fiscal years.

✅ Providing Compliant and Audit-Ready Output

The matrix output is structured precisely to meet Germany’s transfer pricing documentation expectations and integrates seamlessly into local file and master file structures as required under BEPS.

✅ Minimal Manual Intervention

Only two fields—transaction volumes and non-standard taxation status—need to be filled in manually where applicable.

Conclusion

Countries around the world are becoming increasingly demanding regarding the timely delivery of accurate controlled transactions data and supporting transfer pricing reports.

This new reality requires multinational corporations to adopt a structured, proactive approach to prepare transfer pricing documentation, manage income tax risks efficiently, and comply with evolving transfer pricing regulations across multiple tax jurisdictions.

Software solutions like Reptune are now essential for companies to maintain full compliance, streamline transfer pricing risk assessment, and remain prepared for future tax audits globally.

Want to see how quickly you can generate your German Transaction Matrix or Transfer Pricing Report with Reptune?

Book a demo today and future-proof your global transfer pricing compliance!