Verrechnungspreise und Verfahrensrecht

About the work
The determination and severity of tax enforcement in transfer pricing cases by the tax authorities has reached new dimensions in recent years. Mutual agreement procedures due to double taxation, fiscal court proceedings, criminal investigations are on the increase. In addition, there are special procedural norms and unresolved procedural questions relevant to practice (such as, for example, the legal questions of transfer pricing documentation according to Section 90 (3) AO, which are still unresolved 14 years after their entry into force). Corporations are generally suspected of profit shifting (see the BEPS discussion).
The work shows which specific procedural principles are significant for transfer pricing taxation (national and international) and which rights and obligations result from this for the taxpayer and the tax administration.
The entire issue is presented in a comprehensible manner for transfer pricing practitioners on the basis of case studies with corresponding solution tips.

ContentsOfficial duties to investigate and cooperate, accounting and record-keeping duties, notification and recording dutiesPractical issues of transfer pricing documentationTransfer pricing audit from the perspective of the tax authoritiesLegal situation and practical behaviour in critical audit situationsRequests for submission by the authorities as administrative acts: Formal and non-formal legal protectionCost allocations and service charges: Particularities of the duties to cooperate and provide evidenceLicences for trade marks and group names: Influence of procedural lawReconciliation and arbitration proceedingsConsensual termination of tax auditCompromise on tax audit, reconciliation procedure or lawsuit?International request for information under the EU-AHiGInternational joint tax audits EU, USAAPAs as proactive dispute avoidanceFinancial court proceedingsCriminal tax lawDuty of notification for international.