With BEPS (Base Erosion and Profit Shifting), the OECD intends to harmonise the principles for assessing transfer prices internationally. However, the resulting recommendations and amendments continue to allow a great deal of room for interpretation and the implementation in local law is inconsistent.
At the same time, the pressure on taxpayers in tax audits at home and abroad has greatly increased. The potential for conflict and the risk of double taxation continues to increase. This requires a sustainable strategy and stringent approach from taxpaying companies in order to meet this challenge.
We support you in the substantive and formal defence of transfer pricing in the context of tax audits as well as any related litigation and dispute resolution proceedings.
Our services include the following:
- The pro-active development of tax audit strategies, taking into account various courses of action for a possible dispute resolution,
- the preparation and support of tax audits, including the support of coordinated international tax audits (joint audits) and simultaneous audits
- the preparation and implementation of opposition proceedings,
- the preparation, coordination and implementation of cross-border mutual agreement and arbitration proceedings (MAP, EU Arbitration),
- the preparation and support of fiscal court proceedings (FG, BFH) and
- support in criminal tax proceedings relating to transfer pricing.
Partner, National Leader of the Global Transfer Pricing Service Line, Tax
KPMG AG Wirtschaftsprüfungsgesellschaft