The Resource No retroactive application of Sec. 1(3) of the Foreign Tax Act to business restructurings before 2008

No retroactive application of Sec. 1(3) of the Foreign Tax Act to business restructurings before 2008

Label
No retroactive application of Sec. 1(3) of the Foreign Tax Act to business restructurings before 2008
Title
No retroactive application of Sec. 1(3) of the Foreign Tax Act to business restructurings before 2008
Creator
Subject
Language
eng
Summary
This article explores when the new German rules on transfers of functions (business restructuring) apply to taxpayers with different financial years. Moreover, it illustrates that the retroactive application of these rules does not meet the necessary requirements under constitutional law, so that the rules can be applied in a lawful manner only to transfers taking place in tax assessment periods from 2008 onwards
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 16 (2009),
http://library.link/vocab/creatorName
Andresen, U
Geographic coverage
European Union
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing adjustment
  • reorganization
  • retroactivity
Label
No retroactive application of Sec. 1(3) of the Foreign Tax Act to business restructurings before 2008
Instantiates
Publication
Label
No retroactive application of Sec. 1(3) of the Foreign Tax Act to business restructurings before 2008
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...