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minimum term of a profit transfer agreement on the tax recognition of the affiliation relationship

Hesse FG, Judgement 12 K 4273/01 of 15 November 2006 (not final - BFH-Az. IV R 38/07)

orientation sets

• The required minimum duration of a profit on the tax recognition of affiliation relationship has five full time year amount.
  
• Starts the transfer agreement in a short fiscal year, the minimum term shall include the sixth full year.