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NEW WORLD OF INTERCOMPANY FINANCING IN GERMANY
June 28 @ 11:00 am - 12:00 pm EDT
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Participants of the free live webinar will be eligible for 1 CPE credit.
Used as a tax optimization mechanism, intercompany financing in Germany has seen increased use and as a result, increased scrutiny over the last few years. In 2021, the German Ministry of Finance published a decree regarding transfer pricing, including provisions on intercompany financing. Likewise, the Organisation for Economic Co-operation and Development (OECD) also released guidelines in 2022 on intercompany financing and specifically its impact on existing loans and cash pools.
Learning Objectives
- Describe the new OECD guidelines, the new decrees from the German Ministry of Finance and the new case law of the Federal Finance Court, regarding whether a standalone rating is necessary in each individual case.1
- Discuss the impact for new and existing U.S. companies with operations in Germany.2
- Identify possible solutions and next steps to justify intercompany interest rates (e.g. via rating analyses).

Anke Krueger, Managing Director, International Tax, BDO USA, LLP
Speakers
Dr. Henrik Meyer, Partner, International Tax Services, BDO Germany
Dr. Dirk Elbert, Partner, International Tax Law, Office Managing Partner, BDO Germany
Sean Kim, Transfer Pricing Managing Director, BDO USA