GERMANY Law and Practice Contributed by: Alexander Gottstein, MTR Legal Rechtsanwälte
eral APAs can provide significant certainty on transfer pricing outcomes. 9.2 Other Mechanisms Further tools include binding rulings under Section 89 AO, factual agreements reached in tax audits to the extent legally permissible, and competent‑authority agreements on treaty interpretation where a legal basis exists. Co-operative approaches and early alignment can, depending on the case, reduce the risk of double taxation.
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