Transfer pricing knowledge

Special topics in transfer pricing: An overview

• Understanding the basics: What is transfer pricing and why is it important?
• Which transfer pricing issues are particularly risky?
• What legal and economic principles apply to the determination of transfer prices?

Methods for determining transfer prices in financing transactions

• What types of financing transactions are there, how are they taxed and what is their significance?
• Selection of a suitable pricing method for loans used for short, medium and long-term financing, cash pool, the usual Group-internal tool for short-term financing requirements and for liquidity management, as well as guarantee fees that are incurred when companies in the Group explicitly provide collateral.
• How do you apply the methods and which data sources do you use?

IP in transfer pricing systems: What needs to be considered?

• Why is IP so relevant from a transfer pricing perspective?
• What is behind the DEMPE concept and what exactly needs to be done?
• Best practices for integrated business models and matrix organizations.
• What needs to be done in connection with restructuring and M&A activities?

Special case of relocation of functions

• What is a functional relocation?
• How has the handling of functional relocations developed?
• Best practice in dealing with the relocation of functions.

Risk protection

• Specific, legal and practical requirements for transfer pricing documentation.
• Tax audit management: special features.
• Dispute resolution: What options are there?

Awareness of future risks: What is still to come?