The decision to relocate functions within an international corporation is determined by the price limits of the involved companies in external comparison and the economic price limit from the corporate perspective. Therefore, the individual economic and tax influence factors affect the relocation differently, depending on which price limit they impact. An analysis of these factors allows for the identification of the strengths and weaknesses of the German regulations regarding the tax treatment of function relocations in light of the ideal of a decision-neutral taxation. This leads to a nuanced critique of the existing tax treatment of function relocations, distinguishing between economically justified barriers and undesirable tax obstacles, against the backdrop of optimal resource allocation.