As a result of globalisation, the importance of cross-border rendering of services within a company-group is increasing. We support you in the tax-optimization and efficient documentation of your transfer prices.
As a Tax Law Firm specialised in International Taxation, we have particular expertise in the field of transfer pricing. We
- defend your intra-group transactions and transfer-pricing structures,
- offer tax-optimized planning of value chains
- and help you with the (ongoing) implementation of transfer-pricing strategies including all documentation requirements.
Tax defence of transfer prices:
- Support in tax audits, aiming particularly at long-term settlements of disputes with tax authorities
- Defense of intra-group settlements out of court and in appeal proceedings
- Binational and multinational mutual arbitration procedures (MAPs) and advance pricing agreements (APAs)
Tax-optimized structuring of value chains:
- Supplies and services
- Intra-group financing, cash pooling and factoring
- Licensing of IP, especially trademarks, patents and know-how
- Allocation of costs and services
- Digital business models
- Secondments of presonell
Planning and implementation of transfer-pricing strategies and documentation requirements:
- Implementation of specific transfer-pricing models and methods
- Setting up BEPS-compliant transfer-pricing structures
- Transfer of functions and intangible assets
- Documentation of transfer prices (local and master files) as well as other documentation and reporting requirements
- Country-by-country reporting and cross-border exchange of information
- consultancy on VAT, customs and foreign-trade related issues