Transfer Pricing

Clients benefit from both, management experience and Transfer Pricing  expertise

Successfully resolving transfer pricing challenges requires a holistic approach to the group’s business and balancing often diverging interests within the integrated group (i.e., between entities and divisions, …). Clients benefit from a unique combination of transfer pricing expertise and management experience employed to arrive at solutions meeting both, business and tax requirements.

The service offering Transfer Pricing covers:

Developing and implementing transfer pricing systems

  • transactions with tangible property
  • transactions with intangible properties
  • services

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Documenting existing transfer pricing systems
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Conducting outside evidence work
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Defending transfer pricing policies (audits and litigation)
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Opinions and reviews according to the OECD Guidelines
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The work is conducted according to a jointly developed project plan which also specifies the clients’ necessary contribution. Deliverables and associated workload are tailored to the clients’ needs. Milestone reviews facilitate success tracking and budget control.

Posts relating to Transfer Pricing issues

Six steps to a documentation compliant with the 2017 OECD Guidelines

Abstract The new OECD Transfer Pricing Guidelines concisely present the new tightened documentation requirements1. To align transfer pricing outcomes, i.e., the allocation of taxable income across the group companies, with Read More …

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HTVI / BEPS: Some sort of profit split will be the preferred solution

Summary In practice, properly using ex post evidence may be more challenging than the current guidance implies. Given the complexity of the valuation issues two years of ex-post evidence are Read More …

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Transfer Pricing Channel – Overview

The contrabass Transfer Pricing Channel is a means to share ideas and thoughts originating from my work as Transfer Pricing Economist. Sometimes, a short presentation provides easier access to transfer Read More …

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Transfer Pricing Documentation – more than a matter of duty

The benefit: open up additional profit potential. An integrated group’s transfer pricing policy affects entrepreneurial decisions, performance measurement of both, management and affiliates, as well as the allocation of resources. Read More …

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Develop and implement a European transfer pricing policy for a global construction machinery manufacturer

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Develop and implement a European transfer pricing policy for cars and associated P&A

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Develop, implement, and document a transfer pricing policy for headquarters services

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Give an expert opinion on the transfer prices of a major Japanese OEM for cars and P&A

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Transfer pricing policy review for a multinational automotive supplier

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The required CbC reporting may be an opportunity

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