{"title":"Location Benefits in Transfer Pricing","authors":"G. Bestelmeyer, S. Kluge, D. Probst","doi":"10.59403/3vckxb5","DOIUrl":null,"url":null,"abstract":"Although location benefits are discussed in the OECD Transfer Pricing Guidelines 2022 and the UN Practical Manual on Transfer Pricing for Developing Countries 2021, they play no or only a minor role in German transfer pricing practice. However, it can be assumed that this will change, as a Germany’s Federal Tax Court provides guidance on the consideration of location benefits and even requires them to be taken into account.","PeriodicalId":517680,"journal":{"name":"International Transfer Pricing Journal","volume":"23 1","pages":""},"PeriodicalIF":0.0000,"publicationDate":"2024-05-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":"0","resultStr":null,"platform":"Semanticscholar","paperid":null,"PeriodicalName":"International Transfer Pricing Journal","FirstCategoryId":"1085","ListUrlMain":"https://doi.org/10.59403/3vckxb5","RegionNum":0,"RegionCategory":null,"ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":null,"EPubDate":"","PubModel":"","JCR":"","JCRName":"","Score":null,"Total":0}
引用次数: 0
Abstract
Although location benefits are discussed in the OECD Transfer Pricing Guidelines 2022 and the UN Practical Manual on Transfer Pricing for Developing Countries 2021, they play no or only a minor role in German transfer pricing practice. However, it can be assumed that this will change, as a Germany’s Federal Tax Court provides guidance on the consideration of location benefits and even requires them to be taken into account.