Transfer Pricing

Optimizing return on investment during the build-phase involves effectively managing costs and ensuring timely completion of tasks.

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?

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