Germany - Recent Developments Concerning the Rules on the Transfer of Business Functions
- M. (Markus) Schneider
- International Transfer Pricing Journal, 2011 (Volume 18), No 2
- 17 February 2011
This article considers recent developments in the much-debated German rules on the transfer of business functions, including the scope of application of the new “escape clause” introduced in Sec. 1 Para. 3, sentence 10 (second half sentence) of the Foreign Tax Act and the key aspects of the new Administration Principles – Business Restructurings published by the Ministry of Finance on 13 October 2010.