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German tax authorities' first reaction after the ECJ's Hornbach decision an attempt to limit the damage? Björn Heidecke, Markus Kircher and Janis Sussick

By: Heidecke, Björn.
Contributor(s): Kircher, Markus | Sussick, Janis.
Material type: ArticleArticlePublisher: 2019Subject(s): PRECIOS DE TRANSFERENCIA | ALEMANIA | INCUMPLIMIENTO DEL DERECHO COMUNITARIO | TRIBUNAL DE JUSTICIA DE LAS COMUNIDADES EUROPEAS | UNION EUROPEA | JURISPRUDENCIA In: International Transfer Pricing Journal v. 26, n. 2, March / April 2019, p. 82-86Summary: 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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Disponible únicamente en formato electrónico en la Biblioteca del IEF.

Resumen.

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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