122(Vol.9,no.4) Analysis Draft German Transfer Pricing Documentation, APA Guidelines DR. HEINZ-KLAUS KROPPEN LL.M., This article examines the draft document and draft AND DR. ACHIM ROEDER, M. guidelines for requesting and negotiating an advance pricing agreement with Germany. Ithough Section 9.2 of the ciples on Transfer Pricing of 1983 contains sor basic documentation rules, Germany, unlike . Documentation United n ot have ext The draft guidelines together with its attachmen rules. This situat contain long list of specific documents that could be matically hen conducting a In April, the r pricing audit. The documents an auditor could transfer pricing comments tion betw descriptions of products and services; Respect to I that affect prices; ing Rulings. ond step in th explanation of market conditions; pricing guid gendas for board and directors'meetings; nutes of board and directors' meetings; arket studies, product studies, and project present for tax authorit ment, togeth rules for the forth what coc proposed r audit pra d budget documents; cumentsiments; German wirts e determination of prices do d budget deviation and IVC5. Kropper eb sites and the reau of ing, Ams etail ev- Gerr IV B4-S134 8 Transfer cost sharing 3/22/00);for Klaus, Eig 5 An Text section of th Dr. Heinz-Kla national tax part M.A., is manager with De German transfer pricing oid lan- authori- 61400 Copyright 2000 TAX MANAGEMENT INC., a subsidiary of The Bureau of National Affairs, Inc. TMTR ISSN 1063-2069