German Transfer Pricing Updates Align Arm's-Length Rules, OECD
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German Transfer Pricing Updates Align Arm's-Length Rules, OECD
Germany’s Growth Opportunities Act, applicable as of Jan. 1, highlighted a disparity between the German legislature’s application of the arm’s-length principle for intra-group financing versus OECD transfer pricing guidelines for multinational companies and tax administrations. This has created substantial uncertainty for multinationals, leaving many unresolved questions about application of the new tax legislation.
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