Arm’s Length Nature of a Transfer Price as the Decisive Criterion for Compliance with the Arm’s Length Principle (Not Only) in Treaty Cases

Journal
Germany
International Transfer Pricing Journal 2013 (Volume 20), No. 3
A recent decision of the Federal Tax Court concerned the blocking effect of article 9 of the OECD Model and its derivatives over the special conditions developed in prior jurisprudence of the Federal Tax Court.