Transfer Pricing

Flick Gocke Schaumburg has particular expertise in transfer pricing. This includes the defense of intra-group transactions and transfer-pricing structures, the tax-optimized planning of value chains and the ongoing implementation of transfer-pricing strategies including documentation requirements.

Our transfer pricing clients are mainly large multinational corporate groups and family-owned businesses that operate internationally. We have in-depth expertise in transfer pricing in various sectors including pharmaceuticals and medical technology, automotive, logistics, chemistry, mechanical and electrical engineering, consumer goods, financial services and insurance, wholesale and retail trade as well as hard and software. Our membership of Taxand and close personal ties to other renowned law firms and advisors outside Germany enable us to advise on complex multinational engagements quickly and efficiently.

Advice on tax defense

  • Support in tax audits, aiming particularly at the amicable, long-term settlement of disputes
  • Defense in intra-group settlements out of court and in appeal proceedings
  • Binational and multinational mutual arbitration procedures (MAPs) and advance pricing agreements (APAs)

Tax-optimized structuring of value chains relating to all aspects of the intra-group exchange of supplies and services

  • Supplies and services
  • Intra-group financing, cash pooling and factoring
  • Licensing of IP, especially trademarks, patents and know-how
  • Allocation of costs and services
  • Digital business models
  • Secondments

Planning and implementation of transfer-pricing strategies and documentation requirements

  • Implementation of specific transfer-pricing models and methods
  • Experience in setting up BEPS-compliant transfer-pricing structures
  • Transfer of functions and intangible assets
  • Documentation of transfer prices (local and master files) as well as other documentation and reporting requirements
  • Country-by-country reporting and cross-border exchange of information
  • Tax comparisons
  • VAT, customs and foreign-trade issues

Transfer Pricing Study 2018

Flick Gocke Schaumburg and the management consultants Horváth & Partners have again examined the area of conflict in international transfer pricing. The Transfer Pricing Study 2018 also examines the influence of digitization on transfer pricing.