After almost a decade of intense developments and numerous new regulations, ordinances and administrative principles on transfer pricing in Germany (including the widely commented on introduction of the rules on transfers of business functions), 2011 has been a quiet year. This should not, however, lead to the conclusion that the German Ministry of Finance has shifted its focus away from transfer pricing matters or is taking time to reflect on the comprehensive rules introduced so far before deciding what steps to take next. Lorenz Bernhardt and Michael Jakob of PwC run-through the anticipated tax developments in German transfer pricing.
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