Transfer Pricing

Clients benefit from both, management experience and Transfer Pricing  expertise

Successfully resolving transfer pricing challenges requires a holistic approach to the group’s business and balancing often diverging interests within the integrated group (i.e., between entities and divisions, …). Clients benefit from a unique combination of transfer pricing expertise and management experience employed to arrive at solutions meeting both, business and tax requirements.

The service offering Transfer Pricing covers:

Develop and implement transfer pricing systems

  • transactions with tangible property
  • transactions with intangible property
  • services rendered between group companies

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Documenting existing transfer pricing systems

The mandatory documentation is created from scratch or adjusted to the changing requirements. Significant adjustments may be necessary

  • to comply with changing legal requirements;
  • to adjust the strategy to major changes in the relevant markets
  • to support changes in both, business and decision processes.

Experience suggests that revising an existing documentation to comply with the master file / local file structure and the CbC reporting may also lead to transfer pricing policy adjustments. Such opinions may be part of the transfer pricing documentation.

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Conduct outside evidence work

To demonstrate that the transfer prices are at arm’s length comparables / outside evidence work is essential.

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Opinions and reviews according to the OECD Transfer Pricing Guidelines

Opinions underpin and justify the major features of a transfer pricing policy. They may support clients in discussions with authorities and in litigation.

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The cooperation is based on a project plan

The work is conducted according to a jointly developed project plan which also specifies the clients’ necessary contribution. Deliverables and associated workload are tailored to the clients’ needs. Milestone reviews facilitate success tracking and budget control.

Selected Projects

Transfer Pricing policy review for a multinational automotive supplier

Objective: review and adjust the existing transfer pricing policy to re-focus management on profit and growth and to mitigate associated tax exposure.

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Thoughts on transfer pricing

6 steps to a documentation compliant with the 2017 OECD Guidelines

Abstract The new OECD Transfer Pricing Guidelines concisely present the new tightened documentation requirements1. To align transfer pricing outcomes, i.e., the allocation of taxable income across the group companies, with Read More …

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Transfer Pricing Documentation – more than a matter of duty

The benefit: open up additional profit potential. An integrated group’s transfer pricing policy affects entrepreneurial decisions, performance measurement of both, management and affiliates, as well as the allocation of resources. Read More …

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