Carsten Hüning
Partner, Global Leader Transfer Pricing

Compliance with regulatory requirements in times of “BEPS” and structuring of transfer pricing systems

By several measures with regard to “Base Erosion and Profit Shifting (BEPS)”, the OECD increased its pressure on several countries to tighten the tax framework conditions for companies’ cross-border activities and to intensify the monitoring of compliance with such conditions. The legal environment and the intensified monitoring of transfer pricing issues are in full swing in many countries and also in Germany.

International ramifications

For internationally operating companies this means to monitor compliance with regulatory requirements at home and abroad and to make adjustments, if necessary. This includes in particular the development of corresponding transfer pricing documentations, the establishment of consistent agreements, and the creation of procedural conditions including the definition of responsibilities within the group in connection with the fulfillment of legal requirements: A dynamic process which also applies to the amendment of value-added chains and the shifting of individual activities or intangible assets.


Besides the reduction of risks, Baker Tilly’s Transfer Pricing specialists have placed their consulting focus on consequently using all opportunities emerging from the structuring options related with BEPS. The transfer pricing system’s structuring generates tax benefits for groups of companies and often also significant improvements of business processes.

Interdisciplinary consulting approach

Besides of professional expertise and industry-specific experience, comprehensive transfer-pricing consulting also requires a functioning global network. This is exactly what we offer and, furthermore, our interdisciplinary consulting approach also provides for one-stop practical solutions. Our clients from various sectors include multinational groups and internationally operating family businesses as well as venture capital investors and private equity funds.

In order to exploit existing chances and potentials and to avoid risks, Baker Tilly’s Transfer Pricing specialists will be available to contribute their comprehensive know how.

Our range of services includes:

  • Development and implementation of transfer pricing systems
  • Preparation of transfer pricing documentations and documentation concepts
  • (incl. master file, local file and country-by-country reporting)
  • Advice on relocations of functions and cross-border restructurings
  • Defense consulting during tax field audits and support of mutual agreement procedures, preliminary mutual agreement procedures or legal actions before the tax courts
  • Identification of permanent establishments (PE), calculation of apportionment of PE profits and preparation of the related auxiliary calculations
  • Advice on the structuring of foreign assignments, establishment of procurement companies, tax-related issues in connection with intragroup financing and assessment of possible withholding tax matters
  • Preparation of benchmarking analyses
  • Advice on business processes in the Transfer Pricing sector and preparation of transfer pricing directives.
  • Risk assessment in connection with possible implications of BEPS measures (such as examination of “commission agent models”).