Transfer Pricing

Balancing Risk and Opportunity

Transfer Pricing is regarded as one of the most important and most complex aspects of international taxation since years.

Recent and still ongoing national and transnational initiatives – like the OECD/G20 BEPS-project and subsequent changes of domestic transfer pricing regimes – demonstrate how difficult it is to find consensus about the correct pricing of intercompany transactions.

We help you to achieve that

• the outcomes of your transfer pricing are in line with value creation (action items 8-10 of the OECD/G20 BEPS-project)
• you can efficiently and effectively maintain your transfer pricing system
• the risk of transfer pricing adjustments and penalty assessments by tax authorities is minimised
• you do not incur the risk of the same income being taxed twice.

We are specialised in:

• Reviews and Risk Assessment : We review and analyse the current situation to help you identifying existing risks and finding ways to avoid them
• Transfer Price Planning : We ensure that that your transfer prices are compliant with the applicable laws and practices in a way that you do not overpay taxes
• Policy Design : We assist you in developing robust and efficient transfer pricing policies and help you implementing them
• Documentation and Reporting : We prepare the documentation that is necessary to support your transfer prices and assist you in fulfilling your reporting requirements (like CbCR)
• Advance Pricing Agreement / Ruling : We develop with you the best strategy and the most efficient way to obtain certainty in advance about the acceptance of your transfer price setting
• Dispute Resolution : We help you navigating through the often complex procedures, be it in tax authority enquiries, tax audits, tax courts or Mutual Agreement Procedures