Roughly a year after the highest German tax court held that Germany's standard transfer-pricing statute could not be applied to an interest-free loan from a German resident shareholder to a German related party, even if the funds were used in a foreign permanent establishment (Federal Tax Court decision of April 28 2005 - I R 5,6/02), the German tax authorities have given notice of refusal to acquiesce in this ruling (directive of July 22 2005).
August 31 2005