If you, as a taxable person or as a taxable company, have business relations or shareholdings with companies located in a non-cooperative tax jurisdiction, you must submit extensive records of your business activities.
A tax jurisdiction is considered non-cooperative under the Law if it is included in the so-called EU blacklist as well as the national Tax Haven Defense Ordinance (StAbwV).

You must submit:

• A representation as well as an overview of the type and scope of business relations. This includes in particular the purchase of goods, services, loan relationships, insurance relationships, transfers of use as well as cost allocations,
• Contracts and agreed contractual terms on which the business relationships are based,
• a list of agreements relating to intangible assets. This includes cost allocation agreements, research service agreements, and license agreements, as well as a listing of the intangible assets that you use or transfer for use as part of the business relationship in question,
• the functions performed and risks assumed by the parties involved in the business relationship, including changes within the fiscal year,
• the significant assets used,
• the chosen business strategies,
• the market and competitive conditions that are relevant for taxation purposes,
• the natural persons who are directly or indirectly partners or shareholders of the company in the non-cooperative tax jurisdiction with which you have a business relationship. This does not apply if the main class of shares of the foreign company is substantially and regularly traded on a stock exchange in an EU/EEA member state or if the stock exchange is listed by the German Federal Financial Supervisory Authority (BaFin) as an approved stock exchange or other organized market.