Accordingly, there is also a high level of interest on the part of countries to carry out intensive reviews on the topic and to request corresponding transfer pricing documentation and deal intensively with the issue. Over the last few years, numerous tightening of the regulatory framework (including the OECD's ‘Base Erosion and Profit Shifting’ measures) have been introduced in Germany and abroad on the subject of transfer pricing, which must be observed. 

International effects

For internationally operating corporate groups, this means checking compliance with regulatory requirements at home and abroad and making adjustments where necessary. This includes, in particular, the preparation of appropriate transfer pricing documentation, the establishment of a consistent set of contracts and the creation of procedural requirements, including the allocation of responsibilities within the group of companies for the fulfilment of all legal requirements: A dynamic process that applies equally to changes in value chains and the relocation of individual activities or intangible assets.

Stricter regulations in the area of transfer pricing

In addition to reducing risks, our transfer pricing experts have focussed their advice on consistently exploiting all opportunities that arise in the environment of stricter regulatory requirements, including the implementation of BEPS measures, through appropriate structuring options. The structuring of the transfer pricing system thus generates both tax advantages for corporate groups and, in most cases, considerable improvements in operational corporate processes.

Interdisciplinary consulting approach

Comprehensive transfer pricing advice requires not only specialist expertise and industry-specific experience but also a well-functioning global network. This is exactly what we offer you and, in addition, our interdisciplinary consulting approach enables us to provide pragmatic solutions from a single source. Our clients from various sectors include multinational corporations as well as internationally active family businesses, venture capital investors and private equity funds. Baker Tilly's transfer pricing specialists are on hand with their comprehensive expertise to utilise existing opportunities and potential and avoid risks.

Our transfer pricing services

  • Design and implementation of transfer pricing systems
  • Preparation of transfer pricing documentation and documentation concepts (including master file, local file and country-by-country reporting)
  • Advice on relocation of functions and cross-border restructurings 
  • Support with all issues relating to the offsetting of intangible assets (e.g. licensing of brands) 
  • Defence advice in external tax audits and support in mutual agreement proceedings, preliminary ruling proceedings and tax court proceedings
  • Identification of permanent establishments, calculation of permanent establishment profit splits and preparation of the associated auxiliary and ancillary calculations
  • Advice on tax issues in connection with intra-group financing and the preparation of interest benchmarking studies
  • Preparation of benchmarking analyses
  • Advice on procedural corporate processes in the area of transfer pricing and preparation of transfer pricing guidelines
  • Risk assessment with regard to possible effects of BEPS measures (e.g. review of ‘commission agent models’)
Carsten Hüning

Carsten Hüning

Partner, Global Leader Transfer Pricing

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