German Federal Fiscal Court Challenges the Rules on the Application of the AOA for Permanent Establishments

Journal
Karnath, S.; Brugger, H.
Germany
International Transfer Pricing Journal 2025 (Volume 32), No. 5
Format/Price
JournalUSD 45

The article discusses the recent case law of the German Federal Fiscal Court on the application of the Authorized OECD Approach, and its practical implications for the profit determination of permanent establishments.