New developments regarding transfer pricing documentation in Germany

COMPATIBILITY OF THE RECENT OECD PROPOSALS WITH GERMANY'S TAX DISPUTE RESOLUTION MECHANISM - The OECD Centre for Tax Policy and Administration has focused on the problem of international tax disputes and, in this context, examined the effectiveness of the mutual agreement procedure (MAP), which is provided for in tax treaties following the OECD Model Tax Convention and which has been the ...

Dehnen, Peter H., (2006)

RECENT PROBLEMS OF DEFINITION AND TAXATION OF GERMAN PERMANENT ESTABLISHMENTS - The definition of permanent establishment varies from country to country, but the main problem in the tax area is the same: Economically, a PE is simply part of a cross-border company, but for tax purposes, it is to be treated as a separate entity, at least according to the OECD's new approach, which is often referred ...

Dehnen, Peter H., (2005)

NEW DEVELOPMENTS REGARDING TRANSFER PRICING DOCUMENTATION IN GERMANY - Before 31 December 2002, there were no specific documentation requirements in Germany for business transactions between affiliated entities of an international group. The same rules applied to all types of business activities. In 2003, Germany enacted legislation that established extensive cooperation and documentation ...

Dehnen, Peter H., (2005)