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Do you conduct business internationally through your own group companies? If so, cross-border intra-group transactions are likely a regular part of your business. These transactions are subject to the so-called arm’s-length principle, which means that transfer prices for all goods and services must be agreed upon as they would be between unrelated third parties—that is, on arm’s-length terms.
Depending on the volume of intra-group transactions and the size of the company, there are various documentation requirements—ranging from the Master File and Local File to country-by-country reports. The Master File and Local File must be prepared in a timely manner and submitted during tax audits.
We combine in-depth expertise to provide tailored and efficient services for companies operating internationally.
Our Areas of Expertise
1. Transfer Pricing Documentation & Compliance
- Preparation of master files, local files, and country-by-country reports (CbCR)
- Preparation of documentation for extraordinary business transactions (such as transfers of functions)
- Assistance with the drafting of contracts
- Conducting benchmark studies for transfer pricing analysis
2. Strategic Consulting & Design
- Development and support for the implementation of transfer pricing policies and strategies (transfer pricing)
- Planning and support for restructuring initiatives (e.g., international expansion, internal reorganizations)
3. Tax Audits & Defense
- Preparation for and defense during tax audits
- Assistance with mutual agreement procedures (MAP) to avoid double taxation
- Proactive legal certainty through advance pricing agreements (APA)
- Support during arbitration and court proceedings
Your contact person:
Heike Riesselmann
For more information about our transfer pricing services, please visit: