The Resource Draft legislation issued for implementation of Authorized OECD Approach

Draft legislation issued for implementation of Authorized OECD Approach

Label
Draft legislation issued for implementation of Authorized OECD Approach
Title
Draft legislation issued for implementation of Authorized OECD Approach
Creator
Subject
Language
eng
Summary
Germany is about to introduce the Authorized OECD Approach (AOA) in its national tax legislation. This article analyses the draft provision; addresses concerns regarding its compliance with constitutional as well as EU laws and shows how the provision may be misused to broaden the tax base by transfer pricing adjustments in relation to dealings. Further, it shows that taxpayers may not be able to use mutual agreements procedures (MAP) if such adjustments are triggered by non-transfer pricing provisions
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 19 (2012),
http://library.link/vocab/creatorName
Andresen, U
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • AOA
  • EU law
  • MAP
  • treaty override
Label
Draft legislation issued for implementation of Authorized OECD Approach
Instantiates
Publication
Label
Draft legislation issued for implementation of Authorized OECD Approach
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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