No surprises: Ministry of Finance clarifies that it never wanted to introduce the price-setting approach into German transfer pricing rules
On 10 December 2019, the German Federal Ministry of Finance published a draft bill of the so-called ATAD Implementation Act (“ATAD-UmsG“) by which the second European Anti Tax Avoidance Directive (“ATAD II”) should be implemented into German national law. This draft not only contained amended provisions related to the already existing German CFC rules and …