156 ITPJ JULY/AUGUST 2000 Case Notes GERMANY Tax Court Ruling on Transfer Prices and External Gross Margin Analyses! Dr Heinz-Klaus Kroppen2 and Axel Eigelshoven3 I. INTRODUCTION lated ing in the same industry. T The determination of arm's length transfer prices and the comparables were, however, not disclosed to the tax- OF SECRET COMPARABLES before the ne amount of the construc- le price method, with DSIRE)20 der vogele, have not been literature. T ther analysed tax o between th tributor on the