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