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TPDoctor: German transfer of functions legislation

July 08, 2009

A Polish contract manufacturer for Plastic AG, a German entrepreneur, delivers the final goods directly to a customer. Now Polish SA takes over and invoices the customer. Does this trigger any German taxes?

The German 'Plastic AG' (P AG) acted as entrepreneur for certain plastic products and manufactures semi-finished goods in Germany. The final assembling was relocated to a 'Polish SA' years ago. The Polish SA acts as contract manufacturer for P AG and is remunerated based on the cost plus method. For final assembling purposes necessary semi-finished goods are purchased from P AG. Now invoicing is assumed by Polish SA.

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