On 21 October 2021, the German Federal Fiscal Court published its 18 May 2021 decision, IR 4/17. This decision is predicted to have significant implications when determining interest rates for intercompany financing transactions using the comparable uncontrolled price (CUP) method.

In “Court Backs CUP Approach to Intercompany Loans in Germany,” an article published in the International Tax Review, NERA Managing Director Dr. Yves Hervé and Associate Director Dr. Jens Rubart explore the changes that will result from the decision and how it will affect taxpayers in Germany.

The authors also discuss the views of German tax auditors, how German taxpayers can navigate IR 4/17, and the next steps German taxpayers should take considering Federal Fiscal Court decisions.

To read the article, please visit here.