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

Examples of relevant credentials

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