Germany: Transfer pricing regulations derailed by high court decision?

A decision handed down in early May 2001 by Germany's highest tax court indicates that key provisions of the proposed regulations on transfer pricing documentation requirements have no legal foundation and are therefore invalid. Further delay in issuing final documentation regulations may now b...

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Bibliographic Details
Published in:International tax review 2001-07, Vol.12 (7), p.78
Main Author: Vogele, Alexander
Format: Magazinearticle
Language:English
Subjects:
Compliance
Cooperation
Court decisions
Documentation
Law
Proposals
State court decisions
Tax assessments
Tax audits
Tax courts
Taxpayers
Transfer pricing
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Summary:A decision handed down in early May 2001 by Germany's highest tax court indicates that key provisions of the proposed regulations on transfer pricing documentation requirements have no legal foundation and are therefore invalid. Further delay in issuing final documentation regulations may now be expected as the Federal Ministry of Finance strives to assess the impact of the Federal Tax Court decision on its transfer pricing policies. The case giving rise to the May 2001 ruling poses a variety of interesting transfer pricing issues.
ISSN:0958-7594