Context:
Tranfer Pricing became more and more important for MNEs as more than 50 percent of all world-wide trade and services are conducted between related parties within one group of corporations. The pricing of goods and services influences significantly the tax revenue of countries. Consequently the legislative bodies of industrialised and emerging nations as well enforced the tax legislation and administrative proceedings in order to secure the own tax basis.
Content:
The book Transfer Pricing in Germany translates the transfer pricing provisions in Germany. After a brief introduction to German transfer pricing regulations in general, the book is devided in three chapters. The German Fiscal Code and Foreign Tax Act are translated as far as the provisions reffer to the transfer pricing principles. Further important sources are the statutory ordinances Documentation of Income Attribution and Relocation of Functions that are translated in extenso. From huge practical importance are several administrative guidelines as for example:
– Income Allocation
– Permanent Establishments
– Cost Sharing Agreements
– Personnel Secondment
– Advance Pricing Agreements
– Business Relationship
– Relocation of Functions
– Intercompany Loans
The index at the end of the book facilitates the access to the different transfer pricing aspects.
Recommendation:
The book Transfer Pricing in Germany allows foreign advisors and companies’ representatives to access the German Transfer Pricing legislation and administrative practice directly. The english translation of the German provisions will help to evaluate facts of the case without having access to the official documents, that are published almost exclusively in German language.
Transfer Pricing in Germany
Translation of important law and regulations
Kratzer/Blesgen
Softcover, 382 Seiten
1. Edition, published 2012 by Verlag Dr. Otto Schmidt, Cologne
ISBN: 978-3-504-26014-9
