Abstract

Although location benefits are discussed in the OECD Transfer Pricing Guidelines 2022 and the UN Practical Manual on Transfer Pricing for Developing Countries 2021, they play no or only a minor role in German transfer pricing practice. However, it can be assumed that this will change, as a Germany’s Federal Tax Court provides guidance on the consideration of location benefits and even requires them to be taken into account.

Full Text
Published version (Free)

Talk to us

Join us for a 30 min session where you can share your feedback and ask us any queries you have

Schedule a call