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Financial Court of Düsseldorf rules on transfer pricing adjustments

|Approved Changes|Germany-United Kingdom
Germany-United Kingdom

In a recently published decision of 19 February 2008, the Financial Court of Düsseldorf (Finanzgericht Düsseldorf) ruled on the application of Sec. 1 of the Foreign Tax Act (FTA) and expressed doubts about that provision's compatibility with EC law. Details of the decision are summarized below.

(a) Facts. The plaintiff, a German resident, held a 75% participation …

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