German Federal Fiscal Court ruling contradicts position of German Ministry of Finance on Guidance on Financing Structures

Executive summary
The German Ministry of Finance (MoF) issued the Administrative Principles regarding Transfer Pricing (AP TP) in July 2021. This guidance provides, among others, that for loans to German borrowing group affiliates the acceptable interest margin for a foreign financing company is limited to the current risk-free market return unless the financing company is “able and authorized” to …
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