Specifics of Permanent Establishments in Germany

Sun Aug 01 16:24:00 EDT 2010
By Dr. Alexander Voegele with former NERA Analyst Chunyu Zhang

In this issue of BNA International's Transfer Pricing Forum, NERA Special Consultant Dr. Alexander Voegele and former NERA Analyst Chunyu Zhang examine a number of issues affecting  the transfer pricing of cross-border business restructurings in Germany. Apart from the US, Germany is one of the first OECD countries to have introduced extensive transfer pricing regulations for cross-border business restructurings. The authors describe the valuation of transferred functions and intellectual property (IP) and show how to obtain the economic ownership in such IP, how to split the values between the contributors to this IP, and how to calculate the respective license fees and other remunerations.