Interpretation of the arm's length principle under Art. 9 of the OECD Model tax Treaty : does the arm's length principle cover formal requirements?

Type

Journal

Author

Kroppen, H-K.; Rasch, S.

Published Date

January 1, 2004

Issue

International Transfer Pricing Journal 2004 (Volume 11), No. 1

Deals with German case law on the matter of whether Art. 9 of the OECD Model covers formal requirements.