Transfer Pricing for the International Practitioner -- Germany
1 April 2010
By Dr. Alexander Voegele and Chunyu Zhang
In this issue of BNA International's Transfer Pricing Forum, a range of experts from various jurisdictions discuss issues related to the "recharacterization" concept discussed in the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Dr. Alexander Voegele and Chunyu Zhang, based in NERA's Frankfurt office, examine the ways in which the German legislation and jurisprudence replaced the recharacterization by adjustments based on the prudent business manager concept.
