Transfer Pricing

Balancing Risk & 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