Extract to table

482-1(c) sets forth the best method rule, which provides that the arm's-length result of a controlled transaction must be determined under the method that, under the facts and circumstances, provides the most reliable measure of an arm's-length result

Under Section 1 AStG, income from a foreign business relationship must be determined based on the conditions that would have been agreed between unrelated parties acting at arm's length

The Gewinnabgrenzungsaufzeichnungsverordnung ("GAufzV"), the German regulation on profit delineation documentation, specifies the detailed requirements for transfer pricing documentation that must be maintained by German taxpayers