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Germany - Federal Tax Court Ruling on Relationship between Article 9(1) of the OECD Model Convention and National Income Adjustment Provision

Country:
Germany
Author:
X. Ditz; M. (Markus) Schneider
Issue:
International Transfer Pricing Journal, 2013 (Volume 20), No 3
Published:
2 May 2013
A recent decision of the Federal Tax Court considered the tax treatment of payments made for services rendered by a Dutch company to its German affiliate. The authors analyse the case and its practical implications for taxpayers.
 
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