Since 2003 wide-ranging statutory oligations have been in place in Germany regarding the documentation of cross-border business relations between affiliated companies. Determining prices in such business relationships – known as transfer prices – increasingly forms the focus of tax audits. Assessing the reasonableness of transfer prices is a key issue in this respect
Failure to observe this statutory documentation regime, which requires taxable persons to observe a multitude of legal regulations as well as comprehensive administrative principles can result in severe sanctions which need to be avoided.
Esche Schümann Commichau develops options towards enabling clients to fulfil the statutory requirements in a workable manner. Our range of services is not limited to defending past transfer prices. We work towards developing sustainable and resilient transfer pricing strategies and support clients in their practical implementation. Our proposed solutions play a part in avoiding double taxation and reducing the tax burden.
Together with our network partners we offer, among others, the following services:
- Preparing transfer pricing documentation
- Defending transfer pricing structures in the context oft tax audits
- Database analyses to preserve arm's length data such as a determination of arm's length licensing fees.
- Conception and implementation of transfer pricing strategies
- Advice on transfer of functions