"TP Analysis during Economic Downturn." Some industries suffer heavily due to high interest rates. What does that mean for transfer pricing? We argue that an analysis based on options realistically available and an adjustment to benchmark studies could be feasible approaches. Enjoy!
Year-end-adjustments are becoming more important for multinationals. The EU published guidance on how to apply year-end-adjustments. We give practical guidance to implement year-end-adjustments. We will also reflect two court decisions from the BFH (17.05.2022) and the Finanzgericht Munich (FG München 27.10.2022). Enjoy!
For more information, please read our Article on Deloitte Tax News:
EU-Kommission: Richtlinienentwurf zu den Verrechnungspreisen veröffentlicht
The Federal Tax Court in Hamburg decided on a very interesting transfer pricing case. The TP adjustment itself was accepted by the taxpayer in the tax audit. But the adjustment mechanism in a tax unity and the higher taxes at the level of the holding without any intercompany transactions was unexpected. This monthly TP Espresso gives an overview of the case and outlines practical consequences. Cheers!
For more information, please read our Article on Deloitte Tax News:
Germany plans to change its transfer pricing legislation for financial transactions. Important changes for the rating approach and the remuneration of treasury functions are expected. This monthly TP Espresso gives an overview of the envisioned amendments. Enjoy!
For more information, please read our Article on Deloitte Tax News:
Wachstumschancengesetz: Implikationen des Bundestagsbeschlusses für Verrechnungspreise
The OECD published a multilateral convention to implement Pillar 1. We summarize the current status in this month TP Espresso. Enjoy!
For more information, please read our Article on Deloitte Tax News:
OECD release of Multilateral Convention for the implementation of Pillar One Amount A