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Transfer pricing planning is facing major challenges. Due to a growing number of disclosure obligations worldwide and an increasing cross-border exchange of information between tax authorities, the transfer pricing practices of companies are becoming more and more transparent for tax authorities. At the same time, the focus is shifting to the alignment of profit allocation and the allocation of personal value creation as well as cooperation in virtual organizations across borders.

A review of existing systems is therefore necessary, but at the same time offers an opportunity to optimize existing structures for tax purposes.

We support you in the conceptualization, planning and simulation of transfer prices and transfer pricing systems. This includes, for example, the structuring of intra-group supply and service relationships, the selection of appropriate transfer pricing methods and the development of strategies for proving arm's length pricing.

Our services include

  • the conceptualization of global transfer pricing systems with the involvement of foreign KPMG experts,
  • the reorganization and tax optimization of value chains (value chain management) and the localization of value drivers and assets (intellectual property),
  • the mapping of virtual organizational forms in the transfer pricing system in line with their value-added contributions,
  • Supporting the relocation of functions or assets, including value determination for tax purposes, and
  • the modeling and simulation of transfer pricing systems for planning purposes.
Services