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In a series of rulings in 2019 and 2020, the German Federal Fiscal Court has abandoned its decades-long ruling practice on implicit group support and the blocking effect of para. 9 OECD Model Tax Convention.
There have been several changes to German Transfer Pricing rules in the past months. Read more for additional information.
On 14 July 2021, the “Verwaltungsgrundsätze Verrechnungspreise” (Administrative Principles Transfer Pricing, in the following “administrative principles 2021”) were published.
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