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Transfer Pricing

Clarity. Documentation. Success.

Transfer pricing and its impact on the tax rate

For internationally active companies, transfer pricing for intra-group deliveries and services has a decisive impact on the tax rate.

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Reliable transfer pricing models

These prices are often subject to strict review or even complete rejection by the tax authorities. We support you in developing and documenting market-based transfer pricing models and assist you in enforcing them vis-à-vis the tax authorities.

Customised solutions

Our strategies are not only compliant, but also creative and adaptable, addressing the specific challenges and opportunities your business faces. We strive to understand and respect your business model in every solution we offer, ensuring that our strategies are perfectly aligned with your goals.

PKF network offers cross-border expertise

Our team consists of experts with extensive knowledge in transfer pricing and international taxation. Thanks to our international PKF network, we also have access to a broad network of transfer pricing specialists around the world.

Our Transfer Pricing Services

  • Preparation of Country-by-Country Reports (CbCR)
  • Preparation of Master Files
  • Preparation of Local Files
  • Documentation of function transfers and extraordinary business transactions
  • Documentation of the DEMPE analyses
  • Preparation of framework local files for all foreign subsidiaries of a German group
  • Conducting benchmarking studies to determine market prices for your intra-group transactions
  • Preparation of a report on the database study
  • Preparation of licence database studies
  • Preparation of financial database analyses
  • Preparation of an arm's length analysis based on a database study
  • Implementation of the results of the database study in your company
  • Joint preparation for a tax audit with you
  • Support during the tax audits
  • Appeal proceedings
  • Proceedings before fiscal courts
  • Mutual agreement procedures
  • EU arbitration proceedings
  • Proceedings under the Dispute Resolution Act
  • Assessment of your current transfer pricing policy to identify potential risks and propose improvements
  • Analysis of value chains with regard to the transfer pricing system
  • Development of transfer pricing strategies
  • Improving your tax efficiency
  • Planning and development of transfer pricing strategies
  • Optimising your supply chain structures for tax efficiency based on your business model
  • Design of a transfer pricing guideline
  • Drafting transfer pricing agreements to implement the Transfer Pricing Directive
  • Operational Transfer Pricing (OTP): Assistance with the operational implementation, automation and monitoring of the group’s internal transfer pricing policy during ongoing business activity
  • Applying for Advance Pricing Agreements (APAs) to safeguard the planning process