Co-written by Alexander Loh
KPMG Germany Webpage
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The Münster Tax Court has upheld fines assessed by the tax authorities to compel taxpayer production of cost accounting documents for transfer pricing audit purposes (judgement of 22 August 2000 - 6 K 2712/00 - EFG 2001, 4). The judgement was not appealed and is now final.
1. Facts And Issues
The tax authorities requested the corporation under audit to produce its charts of cost centre accounts (Kostenstellenpläne) for two of the company's 60 departments for use in verifying the appropriateness of transfer prices paid. The charts of cost centre accounts (chart of functional accounts) would reveal the architecture of the company's cost accounting system since all journal expense entries in the financial accounting system were coded to specific cost centres.
