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Germany - German Tax Authorities’ First Reaction after the ECJ’s Hornbach Decision – An Attempt to Limit the Damage?

Country:
European Union,Germany
Author:
B. Heidecke; M. Kircher; J. Sussick
Issue:
International Transfer Pricing Journal, 2019 (Volume 26), No 2
Published:
8 February 2019
In summer 2018, the European Court of Justice found that one of the core German transfer pricing laws might not be fully compliant with EU law. Germany’s Ministry of Finance has now issued its first administrative reaction to this court decision. In this article, the authors explain the legal background for the Court’s decision, outline the regulations in the new German administrative guidance and discuss whether the new guidance can help to resolve the uncertainty for taxpayers.
 
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