Federal Tax Court Ruling on Relationship between Article 9(1) of the OECD Model Convention and National Income Adjustment Provision

Ditz, X.; Schneider, M. (Markus)

Federal Tax Court Ruling on Relationship between Article 9(1) of the OECD Model Convention and National Income Adjustment Provision

Journal

Author

Ditz, X.; Schneider, M. (Markus)

Country

Germany

Published Date

2 May 2013

Issue

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

DOI

https://doi.org/10.59403/25xvvcx

Document

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A recent decision of the Federal Tax Court considered the tax treatment of payments made for services rendered by a Dutch company to its German affiliate. The authors analyse the case and its practical implications for taxpayers.

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Federal Tax Court Ruling on Relationship between Article 9(1) of the OECD Model Convention and National Income Adjustment Provision