Germany - German Transfer Pricing Rules Incompatible with EU Law – A Critical Assessment of the ECJ’s Hornbach-Baumarkt (Case C-382/16) Decision
- X. Ditz; C. Quilitzsch
- European Taxation, 2019 (Volume 59), No 4
- 13 March 2019
In this note, the authors examine the ECJ’s decision in Hornbach-Baumarkt (Case C-382/16), which addresses whether or not section 1 of the German Foreign Tax Act, which provides for income adjustments to non-arm’s length transfer prices in respect of business relations with non-resident related parties but not in respect of purely domestic transactions, breaches EU law.