For internationally active companies, transfer pricing has been the focus of every external tax audit for a good 15 years now. Compliance with the arm’s length principle for all intra-group transactions and its documentation pose major challenges for taxpayers.
Every taxpayer must ask themselves the following questions, among others:
Are my transfer prices in line with the arm’s length principle?
Do I have transfer pricing documentation that complies with the provisions of the German Fiscal Code?
What are the implications of the regulations on functional relocation and base erosion and profit shifting (BEPS)?
How can I avoid double taxation for the group in the event of an income adjustment following an external audit?
As transfer pricing specialists, we therefore offer you the following consulting services in particular in the context of transfer pricing:
- Strengths and weaknesses analysis of existing transfer pricing documentation or the existing transfer pricing system at an agreed flat rate (quick check)
- Individual design of transfer pricing systems and their implementation, taking into account tax aspects such as VAT or customs duties
- Preparation of benchmarking analyses for the appropriateness analysis with the help of external databases
- Preparation of transfer pricing documentation (e.g. master file, local file and country-by-country reporting) or individual assistance with the preparation of parts of the documentation
- Defence in tax audits (including involvement in ongoing tax audits)
- Support in mutual agreement procedures, advance pricing agreements (APAs) and fiscal court proceedings
- Advice on functional transfers and cross-border restructuring
- Design and documentation of intra-group financing structures, in particular in the context of Section 1 (3d) and (3e) of the German Foreign Tax Act (AStG), and preparation of interest rate benchmarking studies
- Expert opinions on transfer pricing issues
- Advice on establishing or avoiding permanent establishments, including the allocation of permanent establishment profits and the preparation of the associated auxiliary and supplementary calculations, if necessary
- Risk assessment of potential impacts of BEPS measures
- Conducting workshops, developing guidelines, transfer pricing guidelines and providing support during the implementation of the developed processes
- Coordination with foreign consultants
- Support with issues relating to the transfer pricing of intangible assets (e.g. brand licensing)