Transfer Pricing
The price is right!
Globalization and the gradual removal of international trade barriers have resulted in a steady increase in the volume and the number of intercompany transactions.
According to estimates of the Organisation for Economic Cooperation and Development (OECD) intercompany transactions already account for more than 60 % of world trade.
The Transfer Pricing topics in this context related to the supply of goods and services within one group constitute a highly complex issue. Every single country - including EU member states - has its own regulations. Also in most countries Transfer Pricing is under permanent discussion with the tax authorities.
Only a thorough knowledge of the relevant rules and regulations, guidelines and implementation requirements can prevent double taxation, penalties or other legal consequences. The diligent design of intercompany transactions and relocation of corporate functions including proper documentation are hence an absolute must. On this basis, an accurate Transfer Pricing policy provides the opportunity to moderate taxes and to optimize the profit of your business.
Our services at a glance
Planning and optimization of Transfer Pricing systems
- Assistance with the determination of appropriate transfer prices
- Analysis and adjustment of existing systems for the optimized allocation
of resources and avoidance of double taxation - Integration of different Transfer Pricing systems in case of Mergers
and Acquisitions - Preparation of credit rating analyses within the framework of thin capitalization rules
- Advice on the tax optimization of value added chains
- Simulation of alternative scenarios on the basis of Transfer Pricing models [financial modelling]
Documentation of Transfer Pricing systems
- Preparation of global documentation studies pursuant to national and international
guidelines - Preparation of internal Transfer Pricing guidelines
- Enhanced awareness and coaching of employees on the topic of Transfer Pricing
- Implementation of IT-based solutions for analysis and documentation
- Documentation of the Transfer Pricing system by means of functional, risk,
value added contribution and benchmark analyses - Preparation and documentation of intercompany agreements
Advice on business restructurings and the relocation of company functions
- Individual assessment of transfers of tangible and intangible assets
- Assistance with the evaluation of transfer packages
- Determination of the earning value of individual functions
Defence of Transfer Pricing systems
- Defence of existing systems in external tax audits as well as in mutual agreement and arbitration procedures
- Advice and assistance in negotiations of Advance Pricing Agreements [APA]
Our service approach
Our experts in the field of Transfer Pricing have gained many years of experience in international consulting firms as well as in tax departments of renowned international groups. We have a practice-oriented approach and we are committed to develop creative and pragmatic solutions. Finding practical solutions also means keeping an eye on future developments and the resulting requirements in this field.
