Special rules apply for so-called base shifting (Funktionsver-lagerungen)
Special rules apply for so-called base shifting (Funktionsver-
lagerungen), which involves the transfer of business functions,
including opportunities, risks, and assets. It is possible to deter-
mine individual transfer prices for all components of the transfer
package, provided that at least one substantial intangible asset
is transferred and specifcally identifed by the taxpayer.
This provision is applicable retroactively as of the assessment period
2008. The Federal Ministry of Finance issued the Administrative
EU Forecast
euf:ba.18g:35/nws-01