Global Transfer Pricing

Transfer pricing is a challenging and potentially expensive tax issue for multinational companies. In the current global economic environment, tax authorities around the world are keen to protect their tax base and have an increasing focus on transfer pricing.

The potential cost of not implementing appropriate transfer pricing is an adjustment upon a transfer pricing audit, potentially with penalties and double taxation.

Moreover, considering the current public discussion about the tax practice of multinationals and the initiative of the OECD on Base Erosion and Profit Shifting – “BEPS“ – it can only be expected that transfer pricing requirements will become increasingly complex in most jurisdictions around the world.


Our services in Transfer Pricing

  • Pragmatic TP policy solutions
  • Global TP risk assessment
  • Supply chain advice, planning and optimisation
  • Advice on intercompany transactions involving Intellectual Property
  • Comprehensive economic analysis and benchmarking
  • Credit rating analysis and determination of arm’s length interest rates
  • Financial modelling
  • Value contribution analysis
  • BEPS impact analysis


  • Preparation of OECD-compliant and local country TP documentation
  • Review of Country-by-Country Reports
  • Preparation of documentation in a Master File and Local File format
  • Operational TP guidelines
  • Implementation of TP policies into internal accounting systems
  • Preparation and documentation of intercompany agreements


  • Comprehensive cross-border business restructuring advice
  • Valuation of intangible assets
  • OECD Chapter IX analysis and documentation of business restructuring
  • Determination of the earning value of individual functions


  • Advice and assistance in the negotiation of Advance Pricing Agreements (“APAs”) and Advance Thin Capitalisation Agreements (“ATCAs”)
  • Defence of TP policies in external audits by tax administrations and litigation
  • Advice and assistance with the Mutual Agreement Procedure


Current Issues

Should you have questions our partners are happy to assist:

Maik Heggmair

Tel.: +49 89 286 46-212

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