In the field of international tax law, a special focus lies on transfer pricing advice. Our services cover the entire bandwidth of transfer pricing from design, planning, risk assessments up to the documentation and defense in tax audits.

In the preparation of transfer pricing documentation, we rely on a far-reaching unification of processes in the group. Often, documentation processes can be optimized – either by implementing appropriate modules as a web-based solution internally or by creating the documentation for you as your advisor using field-proven documentation solutions. Let us help you to optimize the time and financial effort for your transfer pricing documentation.

Our services in detail:

ID_einzeln copy  Advisory:

  • Implementation of new transfer pricing systems or changes of existing transfer pricing systems by
    • development of design alternatives
    • business analyses
  •  Advice on business restructuring including the application of German regulations on the transfer of business functions
  • Tax advice when creating intercompany agreements (e.g. on services, supplies, cash pooling, loans, assignment of staff)
  • Negotiation and implementation of Advanced Pricing Agreements
  • Applications for binding information (“Verbindliche Auskunft”) in cases of doubt

ID_einzeln copy  Documentation:

  • Preparation of transfer pricing documentations
    • according to German regulations
    • according to OECD/EU master-file/country-file approach
  • Implementation of standardized group-wide documentation processes including software solutions together with our affiliate Universal Units GmbH
  • Professional advice on the introduction of transfer pricing software in collaboration with Universal Units GmbH
  • Process implementation for the transposition of new regulations on country-by-country reporting including the use of software

ID_einzeln copy  Support in Tax Audits

  • Defense of transfer prices
  • Safeguarding the continuity of tax audit results for the future with binding rulings
  • Mutual Agreement Procedures based on DTT provisions or the EU Arbitration Convention as a prevention against double taxation