Menu
  • Locations
  • Services
  • Experts
  • Hot Topics
  • News & Knowledge
  • Career
  • About us
  • Search
  • Press
  • Events & Webinars
  • Contact
  • Language
  • Berlin
  • Cologne
  • Dusseldorf
  • Erlangen
  • Frankfurt
  • Hamburg
  • Hannover
  • Kolbermoor
  • Munich
  • Nuremberg
  • Regensburg
  • Rosenheim
  • Stuttgart
  • Tax
  • Legal
  • Advisory
  • Industries
  • Digital Solutions
  • DAC 6
  • ESG
  • FISG
  • Pillar Two
  • Tax Internal Control Framework
  • Brochures
  • News
  • Newsletter overview
  • Newsletter subscription
  • Overview
  • Culture
  • How we work
  • You&WTS
  • TALENTnetwork
  • Apply now
  • What Makes Us Stand Out
  • Our Clients
  • Our Employees
  • Awards
  • Corporate Responsibility
  • Our Management Team
  • Our History
  • Our locations
  • by Topic
  • Digital
  • Environment
  • Social commitment
  • Employee responsibility
  • Diversity
  • Press
  • Events & Webinars
  • Contact
English
German
  • English
  • German
WTS worldwide
  • WTS Global
  • Albania
  • Angola
  • Argentina
  • Armenia
  • Australia
  • Austria
  • Bangladesh
  • Belarus
  • Belgium
  • Benin
  • Bolivia
  • Bosnia & Herzegovina
  • Brazil
  • Bulgaria
  • Burkina Faso
  • Burundi
  • Cambodia
  • Cameroon
  • Canada
  • Chile
  • China
  • Colombia
  • Costa Rica
  • Croatia
  • Cyprus
  • Czech Republic
  • Denmark
  • Dominican Republic
  • Ecuador
  • Egypt
  • El Salvador
  • Estonia
  • Finland
  • France
  • Georgia
  • Germany
  • Ghana
  • Gibraltar
  • Greece
  • Guatemala
  • Guinea
  • Honduras
  • Hong Kong
  • Hungary
  • Iceland
  • India
  • Indonesia
  • Iran
  • Iraq
  • Ireland
  • Israel
  • Italy
  • Ivory Coast
  • Japan
  • Kazakhstan
  • Kenya
  • Korea
  • Kyrgyzstan
  • Laos
  • Latvia
  • Lithuania
  • Luxembourg
  • Macao
  • Macedonia
  • Madagascar
  • Malaysia
  • Mali
  • Malta
  • Mauritius
  • Mexico
  • Moldova
  • Mongolia
  • Montenegro
  • Morocco
  • Mozambique
  • Myanmar
  • Nepal
  • Netherlands
  • New Zealand
  • Niger
  • Nigeria
  • Norway
  • Pakistan
  • Panama
  • Paraguay
  • Peru
  • Philippines
  • Poland
  • Portugal
  • Puerto Rico
  • Romania
  • Russia
  • Rwanda
  • Saudi Arabia
  • Senegal
  • Serbia
  • Singapore
  • Slovakia
  • Slovenia
  • South Africa
  • Spain
  • Sri Lanka
  • Sweden
  • Switzerland
  • Taiwan
  • Tanzania
  • Thailand
  • Togo
  • Trinidad and Tobago
  • Tunisia
  • Turkey
  • Turkmenistan
  • Uganda
  • Ukraine
  • United Arab Emirates
  • United Kingdom
  • Uruguay
  • USA
  • Uzbekistan
  • Venezuela
  • Vietnam
  • Zambia
  • Services
    Services

    Learn more about our comprehensive services in the area of tax as well as relevant legal advice and financial advisory.

    Read more
    Tax Legal Advisory Industries Digital Solutions
  • Experts
    Experts

    Our employee structure combines the know-how of industry, consulting, financial management and IT in a very special way. Learn more about our experts.

    Read more
  • Hot Topics
    Hot Topics

    Overview of the current "hot topics" in the tax industry and how we can support with individual questions

    Read more
    DAC 6 ESG FISG Pillar Two Tax Internal Control Framework
  • News & Knowledge
    News & Knowledge

    Here you will find the latest news and topic specials on all aspects of taxation and financial advisory.

    Read more
    Brochures News Newsletter overview Newsletter subscription
  • Career
    Career

    Here you will find an overview of our development and qualification offers as well as employee offers and open positions. We look forward to getting to know you.

    Read more
    Overview Culture How we work You&WTS TALENTnetwork
    Apply now
  • About us
    About us

    Here you will find general information about the structure, special characteristics and history of WTS.

    Read more
    What Makes Us Stand Out Our Clients Our Employees Awards Corporate Responsibility
    Our Management Team Our History Our locations
  • Search
www.wts.de Home Services Transfer Pricing

Transfer Pricing

The extraordinary expertise of our transfer pricing specialists is reflected in numerous publications and lectures at fundamental symposiums and various awards. In 2018 and 2019 WTS Germany was named "Transfer Pricing Firm of the Year" by the well renowned journal International Tax Review.

The calculation and documentation of cross-border intercompany transfer prices is a huge challenge for multinational corporations.

Significant tax risks can arise if transfer prices are not at arm’s length or the respective documentation is insufficient. The consequences include corrections of transfer prices, tax adjustments and interest payments, as well as significant fines in some cases.

In the future, tax authorities will increasingly focus on potential profit transfers in the group for tax optimisation purposes using transfer prices (key term "base erosion and profit shifting – BEPS").

"Compliance" with transfer pricing regulations and and the implementation of internal processes for transfer pricing are also coming to the fore for the management of international corporations, as well as for the tax authorities.

Our clients are international companies and groups from various industries and of various sizes: DAX and MDAX groups but also SMEs.

Each company has its own individual requirements and needs. That is why we work closely with our clients. The level of personal trust is of the utmost importance and is the basis of our advice.

Our transfer pricing experts at WTS are happy to support you with the following issues relating to transfer pricing:

Our WTS experts help to create and implement group-wide transfer pricing documentation systems. This is done in compliance with the current statutory requirements and international standards. The new BEPS requirements make a three-tier documentation approach necessary: overall set-up in a master file (master documentation), local file (company-related documentation) and country-by-country reporting.


An essential tool for proving the arm’s length of intercompany transactions are benchmarking Studies. By now, the process was characterized by high expenditure of time and money as well as subjective decisions. Using an AI, we are able to improve the quality of benchmark studies through more consistent decision-making and make the benchmarking process more efficient.

The artificial intelligence supports the screening process by calculating probabilities for various functions. Thus, a part of the companies can already be excluded automatically; the remaining companies can be processed manually considering the assessment of the AI. A machine learning method, which has been trained based on manually conducted benchmarking studies, calculates the probabilities. For this purpose, the website texts of potential comparable companies are crawled, translated into English, and based on a relative frequency of words, the calculation of probabilities can be performed.

Due to the standardized decision-making by artificial intelligence, we can make more consistent decisions and offer you even higher quality benchmarking studies without negatively impacting the consulting costs. The efficiency gain in our process allows us to increase the number of screened entities.

We would be glad to explain the functionality of artificial intelligence during a live demonstration and answer your questions on this topic.


We help our clients to design and implement internal transfer pricing guidelines. We offer individual and efficient solutions for all company-specific particularities. That way a multionational corporation can raise awareness of the issue of transfer pricing across all levels of the company. At the same time this also makes it possible to identify and avoid any risks at an early stage. In the time of growing mobility of personnel and the ongoing digitalization of working processes this becomes more and more important.


In addition to preparing transfer price documentation reports and guidelines, we also support our clients in the overall planning and optimisation regarding all aspects of their global transfer pricing system. As a result of the BEPS developments it is clear that the calculation of transfer prices and the profit allocation within the group must match the added value contributed by each of the group’s companies. We offer many years of experience and comprehensive specialized expertise in various industries when it comes to performing the necessary economic analyses. We use leeway in terms of design to advise corporate and value chain structures that are optimal from a transfer pricing perspective. Our expertise lies in particular in establishing principal structures, centralising services and redesigning sales models and R&D structures.


In the course of a restructuring regarding the organisational or group structure, we support our clients with the analysis and optimisation of the restructuring form a transfer pricing perspective, as well as with the preparation of the necessary documentation. Even for cross-border business restructurings in the context of the regulations regarding the shift of functions and — related to this, and often necessary — the complex valuation of intangible assets, we offer comprehensive advice from our global network of transfer pricing experts.


Intangible assets are now frequently key value drivers for corporate success and therefore often have a high economic value. They are always the focus of tax audits around the world. It is therefore of vital significance for international companies to plan, implement and consistently document the global development of IP within a multinational group. This may take place, for example, as part of the internal research and development programmes or by analysing matters from a transfer pricing perspective. Besides, the valuation of IP is frequently the starting point for the determination ofg internal arm's length licence fees that apply to the use of IP within a multinational group of companies.


Click here to find out more more.


In recent years, transfer pricing of intra-group financing structures has become the focus of tax administration and jurisdiction.

Due to imprecise and non-binding regulations at the national and international level, this area of transfer pricing bears an increasing potential for uncertainty and risk for taxpayers. We advise our clients comprehensively on the holistic planning and documentation of transfer prices in the field of cross border intra-group financial services in order to effectively reduce the associated risks. In addition, we support our clients in particular by performing quantitative analyses in order to determine arm's length financing conditions, e.g. in the form of specific ratings of group companies, interest rate benchmarks and fee split analyses. Through access to the WTS Global network, international financing structures can also be evaluated multilaterally.


Tax authorities increasingly focus on transfer pricing. We support our clients both in avoiding disputes and in defending transfer prices in tax audits as well as in any legal disputes and dispute resolution proceedings that may result. In doing so, we draw on our comprehensive expertise in court proceedings as well as in out-of-court measures.

Dispute avoidance

  • Planning and conducting Advance Pricing Agreements (APAs)
  • Support in coordinated international tax audits (i.a. Joint Audits and simultaneous audits)
  • Advice on the International Compliance Assurance Program (ICAP)

Dispute resolution

  • Preparation of tax audits, advice on tax audit strategy and comprehensive accompaniment during tax audits
  • Preparation and implementation of opposition proceedings and court proceedings
  • Preparation and implementation of cross-border mutual agreement procedures (MAP) and arbitration proceedings

We provide timely and expert support in clarifying possible consequences abroad with the foreign transfer pricing experts in our worldwide WTS Global network and initiate the necessary steps in good time. We also make use of the relationships of the foreign transfer pricing experts from the WTS Global network to the local tax authorities.


Main Contact
Maik Heggmair
Partner
Certified Tax Consultant
Head of Transfer Pricing / Co-Head Global Service Line Transfer Pricing at WTS Global
Munich
+49 89 28646-212
View Profile
Main Contact
Torsten Hopp
Partner
Certified Tax Consultant, Certified Consultant on International Tax Law
Hamburg
+49 40 3208666-11
View Profile
Main Contact
Prof. Dr. Axel Nientimp
Partner
Head of Transfer Pricing Strategy & Dispute Resolution
Certified Tax Consultant, Specialist consultant for international tax law
Dusseldorf
+49 211 20050-714
View Profile
Main Contact
Andreas Riedl
Partner
Frankfurt
+49 69 1338456-53
View Profile
TP Newsletter #1/2022
Transfer Pricing Newsletter: Update on the recent news and cases in 15 countries
View publication
WTS Global Country TP Guide
View TP Guide
Transfer Pricing Newsletter

With this newsletter, we inform multinational companies on country-specific and international legislative documents and regulations.

Subscribe now
Articles you might be interested in

In this latest edition of the WTS Transfer Pricing Newsletter, our colleagues from 15 countries have provided an update on recently introduced legislations and cases.

Global Transfer Pricing Newsletter #1/2022 now available
read more

There have been several changes to German Transfer Pricing rules in the past months. Read more for additional information

Recent changes on German Tax Law concerning Transfer Pricing
read more

On 14 July 2021, the "Verwaltungsgrundsätze Verrechnungspreise" (Administrative Principles Transfer Pricing, in the following "administrative principles 2021") were published

German Federal Ministry of Finance: Administrative Principles 2021 on Transfer Pricing published
read more

Contact us today

Do you have any questions about our services or WTS? Please let us know. Please fill in our short contact form. We will get in touch with you as soon as possible.

Contact
About us
  • What Makes Us Stand Out
  • Our Clients
  • Awards
  • Corporate Responsibility
  • Quality Process Risk Management
Services
  • Tax
  • Legal
  • Advisory
  • Industries
  • Digital Solutions
Career
  • Overview
  • Culture
  • How we work
  • You&WTS
  • Apply now
News & Knowledge
  • COVID-19 Crisis team
  • Base Erosion and Profit Shifting (BEPS)
  • Tax Internal Control Framework
Transfer Pricing
  • Newsletter subscription
  • Newsletter overview
About Us
  • Our CEO
  • Our Board
  • Culture and Leadership
© 2022 WTS Company Information Disclaimer Data Protection Statement