Suchergebnisse für: `transfer-pricing-adjustment` (6 gefunden)

1. 02. Januar 2013

   No transfer pricing adjustment for breaches of formality

   The Supreme Tax Court has rejected a tax office assessment attempt on the basis of a hidden distribution of profits because of a delay in agreeing management charges in writing, saying that the double tax treaty related party provision bases the arm’s length standard on amount, rather than on the reason for, or documentation, of a transaction.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: related party, transfer pricing, managem ...
2. 16. Oktober 2014

   No forgiveness of interest in view of compensating adjustmen ...

   The Supreme Tax Court has held that a taxpayer cannot claim forgiveness of the interest due on the tax payment following a transfer pricing adjustment on the grounds that an associated company had no claim for interest receivable on the corresponding adjustment in its home country.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: interest, transfer pricing adjustment, f ...
3. 22. September 2023

   TP Perspectives: New "Administrative Principles Transfer Pri ...

   On 6 June 2023, the Federal Ministry of Finance published its new principles for the correction of income pursuant to Section 1 External Tax Relations Act on its website. These are to be applied to all open cases with immediate effect. Only the chapter on relocation of functions is applicable to cases that are realised after 31 December 2021.

   Kategorien: Official Pronouncements, Transfer pricin ...

   Schlagwörter: transfer pricing adjustment, Federal Min ...
4. 15. Februar 2018

   European Court of Justice: customs values and the recogniti ...

   In its decision in Hamamatsu Photonics Deutschland (C-529/16) the European Court of Justice (ECJ) held that Articles 28 to 31 of the Customs Code (old version) must be interpreted as meaning that they do not permit an agreed transaction value, composed of an amount initially invoiced and declared and a flat-rate adjustment made after the end of the accounting period, to form the basis for the customs value, without it being possible to know at the end of the accounting period whether that adjustment would be made up or down.

   Kategorien: European Court of Justice

   Schlagwörter: customs, transfer pricing adjustment, cu ...
5. 23. Januar 2013

   Tax & Legal News – Issue 1, January 2013

   In this issue: PwC Reports, Official Pronouncments, Supreme Tax Court Cases, From Europe and From PwC

   Kategorien: Tax & Legal News

   Schlagwörter: Steuern / Tax
6. 05. Januar 2011

   Swiss double tax treaty excludes thin capital rule

   The Supreme Tax Court has held that the thin capital rules in force up to 2007 are in breach of the non-discrimination clause in the Swiss double tax treaty.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Non-discrimination, thin capital rules, ...