Transfer pricing is of fundamental importance for internationally operating corporate groups. Cross-border settlements have a major impact on the allocation of taxes between the countries concerned and have a decisive influence on the corporate groups’ tax ratio. From a business perspective, too, the system and level of transfer prices are of central importance for companies.

 

Accordingly, the states have a strong interest to conduct intensive reviews on the subject and to request corresponding transfer pricing documentation and to deal intensively with the issue. Over the last few years, numerous stricter regulatory conditions (including the OECD’s “Base Erosion and Profit Shifting” measures) have been introduced on the subject of transfer pricing in Germany and abroad, which must be taken into account. 

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.


Tighter regulations in the area of transfer pricing

In addition to reducing risks, our transfer pricing experts’ consulting focus is on the consistent exploitation of all opportunities that arise in the environment of stricter regulatory requirements, including the implementation of the BEPS measures, through appropriate structuring options. Thus, the design of the transfer pricing system generates both tax advantages for corporate groups and, in most cases, significant improvements in operational 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 services in the field of Transfer Pricing

  • 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
  • Support in all issues related to the charging of intangible assets (e.g., licensing of trademarks)
  • 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 tax-related issues in connection with intragroup financing and preparation of interest rate benchmarking studies
  • Preparation of benchmarking analyses
  • Advice on business processes in the Transfer Pricing sector and preparation of transfer pricing guidelines
  • Risk assessment in connection with possible implications of BEPS measures (such as examination of “commission agent models”)

Carsten Hüning
Partner, Global Leader Transfer Pricing