International companies find different market conditions at the various locations where they work, along with different cost and earnings structures and other variations in price-relevant factors.

Thus it is only too understandable, when it comes to making cross-payments within the group, that these companies should want to take these varying conditions into account. The tax authorities in the different countries, however, often refuse to recognise variations in transfer pricing and in profits.

German tax law corrects these transfer prices under he terms of the External Taxes Act or on the basis of concealed dividends. Should transfer prices not be designed appropriately, the consequence will be multiple taxation and penal surcharges.

We assist our clients in designing transfer prices, by optimising their benefits, such as clear demarcation of authorities, a high level of flexibility when making decisions within a unit, and market-oriented design of intra-company order correlations, analysing the company’s structure and adapting transfer prices to national and international regulations in an optimum way.

The primary aim of our consultancy is to avoid dual taxation and pena surcharges and to use the advantages of decentralised corporate structures in the best way possible.



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