For internationally-active companies, transfer pricing has been the focus of every tax audit for more than 15 years. Compliance with the arm's length principle for all intra-group transactions and their documentation presents taxpayers with major challenges.
Each taxpayer must ask himself the following questions, among others:
Are my transfer prices compatible with the arm's length principle?
Do I have a transfer pricing documentation that complies with the regulations of the German Fiscal code?
What are the effects of the provisions on transfer of functions as well as on base erosion and profit shifting (BEPS)?
How can I avoid double taxation for the group in case of an income adjustment through a tax audit?
As transfer pricing specialists, we therefore offer you the following consultancy services in the context of transfer pricing:
- Strength and weakness analyses of the existing transfer pricing documentation or the existing transfer pricing system at the agreed flat rate (Quick-Check)
- Individual organisation of transfer pricing systems and their implementation taking into account tax aspects such as VAT or customs
- Preparation of benchmarking analyses for arm's length tests with the help of external databases
- Preparation of transfer pricing documentation (for example, Master file, Local file and Country-by-Country Reporting) or individual help in creating sub-sections of the documentation
- Assistance with tax audits (including involvement in ongoing tax audits)
- Assistance with Mutual Agreement Procedures, Advance Pricing Agreements (APAs) as well as financial litigation
- Consultancy on transfer of functions and cross-border restructuring
- Organisation of intra-group financing structures
- Expert opinions on transfer pricing issues
- Consultancy on permanent establishments (or their avoidance) including the allocation of profits between head office and permanent establishment as well as preparation of the accompanying auxiliary and secondary calculation as required by German law
- Risk assessment of possible effects of the BEPS measures
- Carrying out workshops, development of transfer pricing guidelines as well as support in the implementation of the developed processes
- Co-ordination with the foreign consultants