Article
Landmark Decision On Start-Up Loss Allocation And Substance-Over-Form In Transfer Pricing: Key Insights For Transfer Pricing And Legal Practitioners
On May 27, 2025, the German Federal Constitutional Court (Bundesverfassungsgericht) issued a landmark ruling (Case No. 2 BvR 172/24) concerning the deductibility of start-up losses within intercompany transactions...
Alvarez & Marsal