Germany releases final administrative principles on transfer of business functions
December 22, 2010The Federal Ministry of Finance (BMF) released the final version of the administration principles for the examination of income allocation between related parties in cases of a cross-border transfer of business functions (Administration Principles – Transfer of Business Functions, referred to as administration principles) on 13 October 2010.
The administration principles contain 81 pages of questions and clarifications concerning the application of Section 1, subsection 3 of the Foreign Tax Code (Außensteuergesetz, AStG) and the Order Decree Law on Transfer of Business Functions (Funktionsverlagerungverordnung, FVerIV).
Further details are available from the Ernst & Young International Tax Alert which can be accessed using the link below:
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