Global Supply Chains in Flux – Strategic Tax Complexity

Global supply chains are under pressure: shifting production sites, geopolitical tensions, evolving regulations, and digital disruption are reshaping logistics and tax landscapes worldwide.

In practice, this means: A new supplier, a different production location, a revised distribution model, a return shipment to a different site, or an updated transfer pricing system can all trigger significant tax consequences – including VAT liabilities, customs duties, sanctions, or profit reallocations. Often all at once, and across multiple jurisdictions.

Your Challenge: Tax Compliance Across the Entire Supply Chain

Tax protection along the supply chain requires a comprehensive consideration of a wide range of influencing factors resulting from regulatory, operational and geopolitical developments. The following section lists key tax issues that must be taken into account on a regular basis in the context of international supply chains.

  • Ensure VAT compliance amid changing logistics and delivery models
  • Design transfer pricing structures that avoid double taxation
  • Navigate rising tariffs and trade barriers (e.g., USA)
  • Meet new customs obligations due to supply chain shifts
  • Fulfill tax requirements for market entry (e.g., India, USA, China)
  • Align contracts and documentation with tax regulations
  • Comply with sanctions (Russia, China, US restrictions)
  • Address ESG-related obligations (CBAM, deforestation-free supply chains, due diligence laws)

Rarely is the answer found in a single discipline. What’s needed is an integrated view – from logistics to transfer pricing, VAT, customs, export control, ESG compliance, and legal structuring.

Our Solution: Integrated Tax Advisory Across Your Supply Chain

At Baker Tilly, we offer a one-stop solution for tax challenges across your supply chain – combining transfer pricing, VAT, customs and export control into one integrated advisory approach. Our experts work together across disciplines to deliver holistic solutions. Powered by digital tools, we ensure full visibility into tax obligations, risks, and opportunities throughout your value chain.

The following matrix illustrates a typical corporate structure where development, procurement, production, central functions, and distribution are located in different countries. At each stage, specific tax and regulatory challenges arise – and we are here to help you address them:

These examples reflect a selection of our broader service offering, which you can explore here: VAT, Transfer Pricing, Customs & Export Control. We take an integrated approach and advise you across your entire value chain – seamlessly across tax and customs disciplines.

 
VAT
Transfer Pricing
Customs & Export Control
Development
  • Cross-border R&D
  • Licensing
  • E-Invoicing
  • Business restructurings
  • R&D remuneration
  • Technology transfers
  • R&D cost relevance for customs

Procurement

  • Import VAT
  • Input tax deduction
  • Intragroup procurement charges
  • Import duties
  • Customs procedures
  • Tariff preferences
Production
  • Intragroup supplies
  • Warehousing
  • Pricing of intragroup supplies 
  • Processing of non-cleared gooods
  • Customs optimization
Central Functions
  • Centralized services
  • VAT grouping
  • Cost allocations
  • IP licensing
  • License fees as customs valuation elements
  • Export clauses
Distribution
  • Cross-border sales
  • VAT registration
  • resturns
  • Commission models
  • Resale pricing
  • Export restrictions
  • Outbound customs duties
Sebastian Billig

Partner

Attorney-at-Law (Rechtsanwalt)

Marion Fetzer

Partner, Head of Indirect Tax

Certified Tax Advisor

Carsten Hüning

Partner, Global Leader Transfer Pricing

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Our Advisory Approach

Globally Coordinated, Locally Implemented

In over 140 countries, with direct access to local regulatory standards, market entry requirements, and customs procedures.

Integrated & Interdisciplinary

Close collaboration between our transfer pricing, VAT, customs, and export control teams ensures comprehensive solutions from a single source.

Technology-Driven & Data-Transparent

We analyze your tax setup using digital tools – in real time, traceable, reliable. This gives you global visibility over obligations and opportunities. 

Aligned With Your Entire Supply Chain

Whether at the start of production, during cross-border trade, in intragroup service flows, or at the customer interface – we understand the tax implications in every phase.

Typical Consulting Scenarios – For Your Supply Chain

  • Restructuring goods flows: Integrated TP, VAT, and customs evaluation for reduced risk and cost
  • Introducing cost-sharing models: VAT classification, legal design, and compliance implementation
  • Relocating production sites: Analysis of customs advantages, pricing logic, and VAT implications
  • Post-merger integration: Seamless integration of new entities into existing tax structures