Transfer Pricing

Tax Consulting

Abbildung von Sascha Meder am Schreibtisch

Transfer pricing for corporations

For all transactions between affiliates (e.g. deliveries of goods, services, cost charges, cost allocations, and staff assignments), the use of appropriate transfer pricing is essential. Our focus is to find pragmatic and feasible solutions for your specific situation. Our services in the area of planning, documentation and defense of your transfer prices includ:

We recommend the "TP-Quick-Check" if you are interested in a quick "high-level review" by a transfer pricing expert. As part of the TP-Quick-Check, which we offer for a lump-sum fee, we discuss potential transfer pricing risks and ideas for improvements.
Based on the TP-Quick-Check results, we are going to propose next steps, tailored to your transfer pricing situation and individual needs.

As preparation for an upcoming tax audit, we review your documents for the following aspects:

  • compliance with German documentation requirements,
  • appropriate usage of the arm's length principle,
  • existence of required contracts and invoices.

As a result of the ›TP-tax audit-check‹

  • we provide documentation update suggestions,
  • identify and quantify risks of adjustment,
  • provide comments regarding your contracts and invoices.

Our ›TP-tax audit-check‹ helps you to assess potential TP risks and helps you to find ways to minimize these risks.

We prepare benchmark studies based on leading and recognized databases, which can be used to find appropriate transfer prices and to defend your existing transfer prices. Before preparing studies for you, we provide advice regarding the search strategy for your particular situation, explain individual possibilities and explain potential actions. As pure database screenings are generally not accepted by tax authorities, we put much attention on the "manual review" of comparable data (companies or license agreements).

We support you in the determination of appropriate transfer prices and the training of your employees in charge of transfer pricing setting and documentation tasks.
As a competent partner, we are always available for questions about transfer prices and also support you in choosing the appropriate transfer pricing method.

According to your needs, we prepare

  • comprehensive transfer pricing documentation or
  • documentation of certain selected transactions or topics.

If your documentation is prepared inhouse, we are happy to be your outside transfer pricing expert and contact person for questions and guidance regarding this specialized area. Besides that, please feel free to ask us for feedback regarding the transfer pricing documentation you have in place.
If you would like to get your employees introduced to and trained on transfer pricing, with the purpose that they take care of this area going forward, we can help you as well. In doing so, our focus is to make them aware about various situations and respective risks of double taxation as well as possibilities to mitigate such risks.
The documentation of your transfer prices will get prepared by TPMeder based on OECD- and in particular German national tax rules (inter alia § 1 AStG, GAufzV, FVerlV, § 90 AO, § 138a AO).
Depending on the size of your company, there is an obligation to create the following documents:

  • Master File,
  • Local File for each country and
  • Country-by-country Reporting.

Examples of important transfer pricing documentation components are stated below:

  • market and competition analyses,
  • functional and risk analysis,
  • value contribution / value chain analysis,
  • presentation of applied transfer pricing method,
  • evidence of appropriate transfer pricing (e. g. benchmark studies).

The preparation of transfer pricing documentation is the first step towards avoiding unpleasant and lengthy discussions during tax audits. However, to the extent that transfer prices, accounts, invoices, financial results and contracts are not in line with each other and necessary updates are missed, this goal is usually not achieved.
In close contact with you and based on your existing processes and procedures, we help with process engineering and improvements. Also cross-departmental coordination will get implemented. One component of your revised processes will be the “during the year review and maintenance” of implemented transfer prices as well as an annual documentation update.
Included subject areas are:

  • creation / optimization of transfer pricing guidelines,
  • analysis of transactions between affiliates,
  • identification of risks (including double taxation) based on the existing transfer pricing system,
  • identification of risks (including double taxation) based on the existing transfer pricing system,
  • efficient implementation of transfer pricing processes and policies,
  • guidance on existing value chains.

Depending on your existing transfer pricing documentation and implemented transfer pricing systems, only a few actions or substantial support is necessary.

  • TP-tax audit-check
  • guidance and support during tax audits,
  • defense of your existing transfer pricing system during tax audits,
  • communication and mediation between you and the tax authorities,
  • advice in appeal proceedings.
  • transfer and relocation of assets,
  • transactions related to intellectual property (IP),
  • function shift,
  • permanent establishments,
  • secondments,
  • cost allocation systems,
  • interim project management to coordinate national and international transfer pricing topics within your company and with other external consultants.

When designing our seminars, we always combine sound theoretical knowledge with practical cases. The integration of real life examples (either examples from the participants or examples from our years of experience) is very important to us and therefore has a special significance.
We offer various training modules and are also happy to adapt the training to your individual needs. Alternatively, we can offer customized seminars tailored to your situation and the training needs of your employees.
Seminars are offered as full or half-day workshops. A combination of modules to multi-day seminars is possible as well.
Seminars are held either in German or English. If you are interested, we also can offer Chinese as a training language.
Examples of offered training modules:

  • Current legal developments and news
    Seminar Type: Update
  • Database (benchmark) studies
    Seminar Type: Special
    e. g. Search strategy, search criteria, selection process, tax authorities’ acceptance?
  • Functional and risk analysis as well as analysis of the value contribution / value chain
    Seminar Type: Special
  • Local file, master file and country-by-country reporting
    Seminar Type: Special
    e. g. Content of these individual documents. Which corporation has to prepare which documentation? Which national and international rules must be followed?