The importance of tax transfer pricing is increasing. Globalisation, the debate on tax avoidance and initiatives at OECD (BEPS) and EU level are increasing complexity. Finance and tax managers are already citing transfer pricing and its documentation as a focal point with a not insignificant risk potential for companies.

But how can business requirements and tax regulations be harmonised? An important success factor is a holistic approach.

Global Transfer Pricing Services

A sustainable transfer pricing system can only be guaranteed if the documentation approach and possible dispute resolution are adequately taken into account during planning and implementation.

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Our range of services

That is our KPMG approach. We support you with:

planning
implementation
documentation
Auditing and dispute resolution

Interfaces play an important role here. Transfer pricing has many points of contact with other topics in your company.

With our interdisciplinary project approach, together with you and KPMG experts from other specialist areas, we not only keep an eye on tax law aspects (e.g. customs law, VAT, withholding tax, etc.), but also consider the effects, for example on the business management logic and process landscape.

We not only have the necessary experience, but also the resources required to develop our clients' transfer pricing systems, implement them operationally, document them regularly and successfully defend them in tax audits worldwide. To this end, we work together with over 1,200 KPMG transfer pricing specialists in our global GTPS network.

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Planning
Implementation
Documentation
Tax audit and dispute resolution

We support you in the conceptualisation, planning and simulation of transfer prices and transfer pricing systems.

Transfer pricing planning is facing major challenges. Due to a growing number of disclosure obligations worldwide and an increasing cross-border exchange of information between tax authorities, the transfer pricing practices of companies are becoming more and more transparent for tax authorities. At the same time, the focus is shifting to the alignment of profit allocation and the allocation of personal value creation as well as cooperation in virtual organisations across borders.

A review of existing systems is therefore necessary, but at the same time offers an opportunity to optimise existing structures for tax purposes.

We support you in the conceptualisation, planning and simulation of transfer prices and transfer pricing systems. This includes, for example, the structuring of intra-group supply and service relationships, the selection of appropriate transfer pricing methods and the development of strategies for proving arm's length pricing.

Our services include, among other things

The conceptualisation of global transfer pricing systems with the involvement of foreign KPMG experts,
the reorganisation and tax optimisation of value chains (value chain management) and the localisation of value drivers and assets (intellectual property),
the mapping of virtual organisational forms in the transfer pricing system in line with their value-added contributions,
Supporting the transfer of functions or relocation of assets, including value determination for tax purposes, and
the modelling and simulation of transfer pricing systems for planning purposes.

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Implementation of a transfer pricing system

No matter how well planned a transfer pricing system is, it is the implementation that determines its success. Both in terms of realising the desired tax effects and its resilience in tax audits at home and abroad.

Successful implementation begins with anchoring the transfer pricing system in the company organisation and the underlying processes. It is important to continuously monitor the contract-compliant implementation by means of process and key figure reporting and the possibility of short-term, but system-compliant/congruent interventions in the form of price adjustments. Depending on the risk assessment, it may be advisable to proactively secure the contract, for example by means of advance agreement procedures.

We support you in implementing your transfer pricing system (operational transfer pricing) in practice. What we can do for you:

The design and implementation of process and transfer pricing guidelines,
Support with the contractual implementation of transfer pricing systems,
Anchoring transfer pricing methods in internal and external accounting (e.g. KPI selection, reconciliation of transfer pricing with cost centre/account structure),
the control and monitoring of transfer prices,
Support in the selection, configuration and implementation of appropriate IT systems for controlling and monitoring transfer prices, and
the development and implementation of AI-supported solutions.

We support you by creating needs-based analyses.

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We support you in fulfilling the statutory reporting, documentation and recording obligations at home and abroad.

With the increasing expansion of record-keeping and documentation obligations and the resulting transparency efforts, a new, in part internationally harmonised documentation approach has been introduced. Depending on the size of the company or group, the tax authorities follow a three-pronged approach consisting of master file, local file and country-by-country reporting. These are subject to different local submission and reporting obligations from country to country.

We support you in fulfilling the statutory information, documentation and recording obligations in Germany and abroad. Our services include the following:

The review and preparation of the master file,
The audit and preparation of the transfer pricing documentation (usually corresponds to the local file) for individual companies or permanent establishments,
Preparation of transfer pricing documentation for groups of companies (including project management and involvement of foreign KPMG experts to ensure compliance with local regulations),
the review and preparation of country-by-country reporting (including public country-by-country reporting and qualified country-by-country reporting for use within the framework of the safe harbour regulations for global minimum taxation) and its transmission to the Federal Central Tax Office, and
the review and design of documentation processes, including the selection, configuration and implementation of IT solutions.

We support you by creating needs-based analyses.

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We support you in the substantive and formal defence of transfer prices.

Even though the various efforts at international level are aiming to harmonise the principles for assessing transfer prices, the existing recommendations and amendments still leave a great deal of room for interpretation and implementation in local law is inconsistent.

At the same time, the pressure on taxpayers in tax audits at home and abroad has increased significantly. The potential for conflict and the risk of double taxation continues to increase. This requires taxable companies to adopt a sustainable strategy and stringent approach in order to meet this challenge.

We support you in the substantive and formal defence of transfer pricing in the context of tax audits and any associated legal disputes and dispute resolution proceedings.

Our services include the following:

The proactive development of tax audit strategies, taking into account various options for a possible dispute resolution,
the preparation and support of proceedings based on the International Compliance Assurance Programme (ICAP) and the European Trust and Cooperation Approach (ETACA),
the planning, preparation and implementation of bilateral and multilateral advance pricing agreements (APAs),
the preparation and support of tax audits, including the support of coordinated international external audits (joint audits) and simultaneous audits,
the preparation and implementation of objection proceedings,
the preparation, coordination and implementation of cross-border mutual agreement and arbitration proceedings (MAP, EU Arbitration),
the preparation and support of tax court proceedings (FG, BFH) and
support in criminal tax proceedings relating to transfer pricing.