In theory it is the same but there will always be slight legal/cultural differences. They have not solidified on SPCs like we have, so if that is the issue get local advice

As Keith says, TUPE came into place via the European Directive 2001/23/EC of 12 March 2001. The directive required member states to transcribe it into national law, and allowed each state to include provisions that are more favourable than those in the initial directive. therefore, in all liklihood the German transposition of the directive will have variants that are very different from the TUPE provisions that we know;
My advice would be to contact a German employment lawyer for help. The major international firms will certainly be able to help you, but there are also some very good national firms.
I have used the IUS LABORIS global network of legal firms over the years and the quality has always been good. I haven't used the German contact but the form there is Kliemt & Vollstadt with offices in Berlin, Düsseldorf and Frankfurt. Google them for contact details if you like.
good luck

In reply to Peter Stanway:

@Peter
Sorry, I should have written "Peter", not "Keith"
Sometimes the brain is slower than the fingers :-)

In reply to Ray:

often my fingers are much faster than my brain