Transfer pricing planning is facing major challenges. Increasing disclosure obligations and the cross-border exchange of information between tax administrations are making transfer pricing practice more and more transparent. At the same time, harmonisation of profit distribution and value creation and the redefinition of the constituent elements of a permanent establishment are coming into focus.
The review of existing systems is therefore necessary, but at the same time offers an opportunity to optimise existing structures for tax purposes.
We support you in the conceptual design, planning and simulation of transfer prices or transfer pricing systems. This includes, for example, the structuring of intra-group supply and service relationships, the selection of appropriate transfer pricing methods as well as the development of strategies for the proof of arm's length.
Our services include:
- The conceptualisation of global transfer pricing systems with the involvement of foreign KPMG experts,
- the reorganisation and tax optimisation of value chains (Value Chain Management)
- as well as the localisation of value drivers or assets (Intellectual Property),
- support in the relocation of functions or assets, including the determination of value for tax purposes, and
- Modelling and simulation of transfer pricing systems for planning purposes.
Michael Freudenberg
Partner, Tax - Head of Global Transfer Pricing Services
KPMG AG Wirtschaftsprüfungsgesellschaft
