Transfer Pricing

Companies operating internationally that have cross-border exchanges of goods and services between the members of their corporate groups (intercompany transactions) have to diligently watch for transfer pricing issues in their intercompany transactions and often must document how their transfer prices were set.

In view of the growing global exchange of goods and services within corporate groups, tax authorities have increasingly focused on them and examine such intercompany transactions in tax and government field audits. The complexity of worldwide transfer pricing regulations in connection with strict tax laws can quickly result in tax risks and repercussions, which should be avoided. That is why is important to have experts with many years of experience in the area transfer pricing at your disposal.

Nexia’s transfer pricing experts can offer you advice on all of the issues surrounding transfer pricing in over 120 countries. Our consulting approach is to support you in planning, setting and documenting transfer prices as well as to defend your transfer pricing policy in a tax or government field audit. We at Nexia are also there with you in dealing with mutual agreement processes. The international  experts of the Nexia network can assist you in fulfilling not only the high tax law requirements specific to Germany but also to those in other countries in which the members of your corporate group are located and in your having successful outcomes in audits and legal disputes.

Our services in the area of transfer pricing are for example:

• Supporting the planning of transfer pricing structures in takeovers and restructurings (M&A)
• Advising on how to establish and design transfer pricing systems
• Reviewing and preparing transfer pricing documentation coordinated and harmonised globally (local files/coordinated transfer pricing documentation)
• Preparing transfer pricing guidelines for meeting tax compliance requirements
• Supporting with special issues such as shifting functions or allocating costs
• Supporting you during tax and government field audits and in mutual agreement processes

Feel free to talk to us with no strings attached – we are glad to see you.

Publications

Public Country-by-Country Reporting (pCbCR): New transparency regulations for companies

Public Country-by-Country Reporting (pCbCR): New transparency regulations for companies

Almost every company today has foreign relationships. While the free movement of capital gives companies more and more opportunities to structure their taxes, the collection of taxes poses a major challenge for countries. The disclosure of income tax information through pCbCR is intended to counteract this tax avoidance and create more transparency.

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Cross-border financing relationships: higher obligation to provide evidence and limitation of interest deduction

Cross-border financing relationships: higher obligation to provide evidence and limitation of interest deduction

The draft bill for the Growth Opportunities Act originally provided for the introduction of an interest rate cap to limit the amount of interest deducted by a company. However, this was removed from the law. Instead, special regulations have been introduced in Section 1 (3d) and (3e) AStG, which specify the arm's length comparison for financing relationships.

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Perspectives on the proposed transfer pricing legislative changes for the European Union

Perspectives on the proposed transfer pricing legislative changes for the European Union

As part of the Business Europe Framework for Income Taxation (“BEFIT”) package, published on September 12th, 2023, a proposal for issuing a European Directive, aimed at harmonising the EU regulatory framework on transfer pricing (“TP Directive”), was issued by the European Commission.

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Do you already have a Transfer Pricing Documentation?

Do you already have a Transfer Pricing Documentation?

Transfer Pricing - Legal requirements for international supply and service relationships between related group entities.

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