Germany strengthens TP regime
February 05, 2008
Andreas Köster-Böckenförde , of Jones Day in Frankfurt, explains the thinking behind recent revisions to TP law
In recent years, the government and its finance finistry have tightened the legislation relating to transfer pricing, seeking not only to offset reductions in the tax rate but also to close the loopholes said to be eroding the German tax base. Historically, transfer pricing was an important issue, primarily with respect to domestic transactions, since German tax authorities focused on the relation of companies to their German resident shareholders rather than on cross-border issues.
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