Germany - Federal Tax Court Ruling on Relationship between Article 9(1) of the OECD Model Convention and National Income Adjustment Provision
- X. Ditz; M. (Markus) Schneider
- International Transfer Pricing Journal, 2013 (Volume 20), No 3
- 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.