Vol. 6 No. 1, January/February ITPJ 3 Recent Developments Germany THE APPLICATION OF GERMAN INCOME CORRECTION RULES TO PARTNERSHIPS HAVING INTERNATIONAL TRANSACTIONS By Dr Heinz-Klaus Kroppen, LL. M and Marc Lubker* The local tax office initially tried to treat the Swiss joint- stock company as letter-box company and attributed all prof- hip is principally deter- its to the German partnership. After negative ruling by the ) However, Tax Court, the tax office supported its income correction by applying Section FTTL. The heirs of the Swiss resident ed suit seeking a suspension, which was granted by the Tax Court. In its ruling, the Tax Court held that Sectio n in this case. The Supreme Tax decision and remanded the case to the IE APPLICATION OF SECTION 1 FTTLTO TERNATIONAL TRANSACTIONS OF A related parties ciple. In the Sectior ax Court c this is the final be discussed folle . THE FACTS Swiss re German partnership (in the sole li of a Sw Swis: the German proposals and tor share of income partnership delivered all all of its costs, and ear on the net value of the good