22.09.2023 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. Categories: Official Pronouncements, Transfer pricin ...Keywords: transfer pricing adjustment, Federal Min ...
31.07.2023 TP Perspectives - Newsflash New "Administrative Principles Transfer Pricing - Principles for the Adjustment of In-come Pursuant to Section 1 of the External Tax Relations Act". Categories: Transfer pricingKeywords: transfer pricing
10.11.2021 Supreme Tax Court: Further landmark ruling on intra-group fi ... The Supreme Tax Court issued a further landmark ruling in the area of intra-group financing by which the court strengthens the consideration of risk premiums for subordinated and unsecured loans. Categories: Supreme Tax Court cases, Transfer pricin ...Keywords: unsecured loan, intra-group financing, s ...
24.10.2021 Supreme Tax Court rules on arm’s length interest on intercom ... In a most recent judgment, the Supreme Tax Court decided on the transfer pricing method to determine an arm's length interest on intercompany loans. In its decision the highest tax court also provides some guidelines on the parameters to be observed from a purely tax point of view. Also, the court takes time to compare the adequacy of the various standard methods under review. Categories: Supreme Tax Court cases, Transfer pricin ...Keywords: arm's length, intercompany loan, compara ...
