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:
As a result of the ›TP-tax audit-check‹
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
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:
Examples of important transfer pricing documentation components are stated below:
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:
Depending on your existing transfer pricing documentation and implemented transfer pricing systems, only a few actions or substantial support is necessary.
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: