Research project: Transfer pricing procedures

• Project direction: Prof. Dr. Andreas Oestreicher, Prof. Dr. Ekkehart Reimer

• Team: Prof. Dr. Andreas Oestreicher, Prof. Dr. Ekkehart Reimer, Dorothée Ohlrogge, Jakob Lanz, Markus Schaupp

• Duration: 1.10.2020 - 30.09.2021

• Funded by: Die Stiftung für Familienunternehmen in Deutschland und Europa

• Goal: Recent studies on tax compliance behaviour have shown that tax compliance is improved if the government supplements the coercive means of enforcing tax claims with measures that create trust in state action. Against this background, it will be examined where possible deficits in tax compliance lie in the area of tax transfer pricing, what the reasons for this are and whether tax compliance can be strengthened through trust in proper administrative action.

From a jurisprudential point of view, the question is examined to what extent confidence-promoting measures can already be realised de lege lata within the framework of the principle of cooperation, where these measures can be implemented by means of legislative amendments while weighing them against the other (procedural) legal principles, and where not even legislative amendments are permissible.