On Oct 28 2021, Markus Brem, GTP® TEAM Leader, as well as Mrs. Ulrike Wolff-Seeger and Mr. Siegfried Müller (both Bavarian Office of Tax Administration) presented their annual one-day seminar on transfer pricing at the Munich Chamber of Tax Consultants. For 14 years, this seminar initiated by GTP® provides for an updated on transfer pricing specifics and is defined as advance course of tax consultants specializing on international taxation.
The focus of this year’s seminar is on the new administrative principles of the Federal Ministry of Finance (Germany) on transfer pricing, income allocation, and documentation. The Ministry released such new guidance on documentation in December 2020 and on transfer pricing and arm’s length analysis in July 2021 – both in the course of new legal provisions set forth in various tax codes. The new guidance refers very close to the OECD Transfer Pricing Guidelines 2017.
Among others, the top case on transfer pricing currently processed by the Federal Tax Court will be presented. This case is about a “small-case taxpayer” with two legal entities and a cost-plus model in place. The lower court ruling was the Tax Court Munich.
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