Arm’s Length Nature of a Transfer Price as the Decisive Criterion for Compliance with the Arm’s Length Principle (Not Only) in Treaty Cases

Andresen, U.; Kerenyi, D.

Arm’s Length Nature of a Transfer Price as the Decisive Criterion for Compliance with the Arm’s Length Principle (Not Only) in Treaty Cases

Journal

Author

Andresen, U.; Kerenyi, D.

Country

Germany

Published Date

6 May 2013

Issue

International Transfer Pricing Journal 2013 (Volume 20), No. 3

DOI

https://doi.org/10.59403/2gf1fjy

Document

Go to Tax Research Platform

A recent decision of the Federal Tax Court concerned the blocking effect of article 9 of the OECD Model and its derivatives over the special conditions developed in prior jurisprudence of the Federal Tax Court.

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Arm’s Length Nature of a Transfer Price as the Decisive Criterion for Compliance with the Arm’s Length Principle (Not Only) in Treaty Cases