If you, as a taxable person or a taxable company, have business relationships or shareholdings with companies based in a non-cooperative tax jurisdiction, you must submit comprehensive records of your business activities.
A tax jurisdiction is considered non-cooperative within the meaning of the law if it is on the EU blacklist and the national Tax Haven Defense Ordinance (StAbwV).

You must submit

• a presentation as well as an overview of the type and scope of business relationships. This includes in particular the purchase of goods, services, loan relationships, insurance relationships, transfers of use and cost allocations,
• Contracts and agreed contractual conditions on which the business relationships are based,
• a list of agreements relating to intangible assets. This also includes cost allocation agreements, research service agreements and license agreements as well as a list of the intangible assets that you use or transfer for use within the scope of the relevant business relationships,
• the functions performed and risks assumed by the parties involved in the business relationship, including changes during the financial year
• the material assets used
• the business strategies chosen,
• the market and competitive conditions that are relevant for taxation,
• the natural persons who are direct or indirect 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 traded substantially and regularly 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 authorized stock exchange or other organized market.