Optimizing return on investment during the build-phase involves effectively managing costs and ensuring timely completion of tasks.
Your key questions, challenges and objectives
- What should be the transfer pricing policy for transactions between related entities that complies with German and OECD regulations?
- How should value chain profits appropriately be allocated among related entities?
- How to treat any intangibles transferred to or developed by your new company in Germany?
- How to treat (potential) start-up losses and initial investments in Germany from a transfer pricing perspective?
- How to avoid double taxation and to be best prepared for future transfer pricing related tax audits?
How we support
- Support with the development of a robust (arm’s length) transfer pricing system under consideration of individual business needs
- Analysis of the entire value chain providing insights into the (tax) appropriate allocation of profits and risks among related entities
- Support with the implementation, monitoring, and steering of transfer price systems to ensure operational efficiency and compliance
- Assistance with preparation of intercompany agreements, and transfer pricing documentation consistent with relevant legal requirements
- Ongoing and transfer pricing support to proactively address emerging transfer pricing issues, regulatory changes, and optimization potential
Ruslan Klauser
Partner, Tax
KPMG AG Wirtschaftsprüfungsgesellschaft
+49 30 2068-1922 Ruslan
Klauser
Phone number
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Get in touch for further questions
Andreas Glunz
Managing Partner International Business
KPMG AG Wirtschaftsprüfungsgesellschaft
+49 211 475 7127 Andreas
Glunz
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Joachim von Prittwitz
Markets, International Business
KPMG AG Wirtschaftsprüfungsgesellschaft
+49 30 2068-4195 Joachim
von Prittwitz
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