Supply chains are under scrutiny. The Supply Chain Due Diligence Act, the coronavirus pandemic, sustainability - there are many reasons to scrutinise and, if necessary, adapt the supply chain within a company. The trend is towards more localised and flexible supply chains, also in order to remain capable of acting in crisis situations. This has an impact on transfer pricing, as every investment and every adjustment within the value chain, such as the relocation of a site or the change of a supplier, may also have to be reflected in the transfer pricing model. From a transfer pricing perspective, there may be risks, but also opportunities.
As part of the increasing sustainability efforts of many companies, topics such as more sustainable production, the insourcing of production steps or social commitment at production sites are also on the agenda. These activities support the development of "green branding". However, with regard to the transfer pricing model, they also quickly lead to the topic of the assessment, valuation and offsetting of (new) intangible assets. The tax authorities are increasingly scrutinising the offsetting of intangible assets, known as "intangibles", as part of tax audits.
However, changes in the organisation of the supply chain generally also have further tax implications, for example on indirect taxes and customs duties, which should be included in the planning.
