When it comes to transfer pricing, we’re the experts. Our specialities include the defense of intra-group pricing and transfer pricing structures, the tax-optimized planning of value chains, and the ongoing implementation of transfer pricing concepts by means of drafting contracts, guidelines and documentation requirements, plus integration into an organization’s tax CMS.
Our clients come from a variety of industries, and include both large multinational corporate groups and family businesses with an international outlook. We have particular transfer pricing expertise in the pharmaceutical/medtech industry and the automotive, logistics, chemical, mechanical and electrical engineering, consumer goods, financial services, insurance, wholesale and retail, and hardware and software sectors.
In every project, we consider the connections between transfer pricing and other aspects of international tax law. Besides having to be at arm’s length, transfer pricing systems are linked to exit taxation, the risk of forming permanent establishments, questions of add-back taxation, withholding tax aspects, interest and licence caps, matters of substance, and other issues under double taxation treaties.
We also advise clients on their transfer pricing calculations and operational transfer pricing. Here, we work with various software providers to improve the efficiency of our clients’ processes with the help of transfer pricing tools.
Our transfer pricing services include:
- Support in tax audits (including joint audits), in particular to achieve amicable, long-term dispute resolution
- Defense of intra-group transfer prices in and out of court
- Conducting binational and multinational mutual agreement procedures and advance pricing agreements
- Supplies of goods and services
- Intra-group financing, cash pools, factoring and financing support
- IP licensing (in particular trademarks, patents, know-how) including the DEMPE functions
- Allocation of costs and services
- Digital business models
- Employee secondments
- Reorganizing and restructuring business models
- Performing economic transfer pricing analyses
- Advice on tool-based operational transfer pricing
- Comparing income tax burdens and performing financial analyses for current and future target structures
- Analyzing and recommending a defensible target structure considering aspects of VAT, customs and foreign trade
- Implementing transfer pricing models and methods with intercompany agreements effective under civil law and transfer pricing guidelines
- Transfer pricing documentation (local and master file) and other documentation and reporting duties, documentation of extraordinary business transactions
- Country-by-country reporting and cross-border sharing of information
- Integrating transfer pricing structures into the client’s tax CMS
When it comes to transfer pricing, our membership in Taxand and close personal contacts with other leading advisors around the world enable us to advise clients quickly and efficiently in complex, multinational engagements. Alternatively, we work with our clients’ existing advisors in other countries.