The control and profit transfer agreement

Measure 1: the control and profit transfer agreement

The control and profit transfer agreement (measure 1

Assessment of the control and profit transfer agreement (measure 1

Payments under the control and profit/loss transfer agreements

It will remove the need for transfer pricing and fights the profit erosion, which is a primary route for profit shifting.

Unlimited opportunities to transfer profits and revenues,

Profit hoarding and profit shifting before the corporate tax reform

Payments under the Financing Guidelines and the control and profit/loss transfer agreements

There was no control- and profit‐transfer agreement between MobilCom and freenet.de AG.

(c) Provide free transfer of profits, capital and other fees.

Negative reinvested earnings are recorded in the second year because reinvested earnings are calculated after remittances of profits.

The remittance of benefits free of tax with no amount or time limitation;

The remittance of benefits free of tax with no amount or time limitation;

Transfer revenue net of tax without any limitation in amount or time