Verrechnungspreise international verbundener Unternehmen

Transfer pricing is a fundamental topic in international tax practice and has gained significant importance.

The new edition of Wassermeyer/Baumhoff/Ditz is up-to-date and ensures legally secure transfer pricing arrangements. It thoroughly addresses all developments and explains them in detail. In particular, the implications of the reform of § 1 of the Foreign Tax Act (AStG) in 2021, as well as the new principles of tax administration as laid out in the Administrative Principles 2020 and the Administrative Principles on Transfer Pricing 2021, are analyzed in a practical manner.

Wassermeyer/Baumhoff/Ditz provides a comprehensive presentation from all legal and business perspectives.

It offers appropriate and practical solutions, design recommendations, and precisely prepared argumentation aids, as well as a comprehensive guide to successfully tackling the challenges in this area.

The new edition takes into account all current aspects, including:

• § 1 of the Foreign Tax Act (AStG) as amended by the ATAD Implementation Act (ATADUmsG) of June 25, 2021, and the Deduction Tax Relief Modernization Act (AbzStEntModG) of June 2, 2021

• OECD Guidelines 2022

• Administrative Principles 2020 of December 3, 2020, and Administrative Principles on Transfer Pricing 2021 of July 14, 2021

• New Federal Fiscal Court (BFH) rulings on group financing.