Transfer Pricing

We begin the (re-)design of transfer pricing models by analyzing functions, risks, and the supply chain. We take all intercompany transactions and transfer pricing methods into account to develop or optimize the appropriate model for you. Central entrepreneur models, transfers of functions or IP, and financial simulations for the transition also play an important role. Through ex-ante benchmarking, we ensure appropriateness and compliance with regulatory requirements.

We implement operational transfer pricing by properly reflecting tax transfer prices in legal books and steering transfer prices in management books. We automate P&L segmentation, transfer pricing forecasting and setting, margin monitoring, as well as year-end adjustments. In addition, we support the design and implementation of software solutions for data gathering and cleaning, margin monitoring, and price setting, including the writing of transfer prices in ERP systems—also within the scope of proof-of-concepts.

We defend your transfer pricing model in regular tax and transfer pricing audits as well as in joint tax audits. Proactively, we assist with Advance Pricing Agreements (APAs), while reactively supporting Mutual Agreement Procedures (MAPs) and representing clients in litigation when necessary.