Related-party transfer pricing rules
Some of these decrees are far-reaching, for example the decree embodying the
related-party transfer pricing rules. As with the guidelines, these decrees do not
have legal force and do not therefore bind the taxpayers or the courts.
In principle, they do not bind the tax authorities either, especially as the authority
issuing a decree can change or withdraw it at any time. In practice, tax offices
will almost always follow a decree, if only because it would be a breach of
discipline for them not to do so. Nevertheless, the decrees only interpret the
law; they are not the law itself. Thus it would be unwise to rely too heavily on a
literal rendering of a decree when taking a position clearly at variance with its
intent.
EU Forecast
euf:ba18e:127/nws-01