Publications

On 5 March 2010, the Lower House of the German Parliament (Bundestag) passed a tax bill easing the provisions regarding the transfer of functions. Pursuant  thereto, in the event of a cross-border transfer of functions it will, under certain conditions, be possible to calculate the fair and reasonable transfer price on the basis of the individual transfer prices of the economic assets being transferred instead of the so-called transfer package. Through this legislative amendment, the governing parties are seeking to hold true to their pledge in the coalition agreeement to redress the tax disadvantages existing in Germany as a location for research and development as a result of the transfer of functions rules. The Upper House of the German Parliament (Bundesrat) is expected to approve the bill on 26 March 2010.