Multinational Corporate Groups need reasonableness to distribute profits to manage the transfer pricing system..

Multinational Corporate Groups need reasonableness to distribute profits to manage the transfer pricing system. The existing, booked data of related parties are the starting point for this; further data and information are added. In this way, all relevant facts and profit distributions can be routinely used to justify appropriateness in the sense of the arm’s length principle.

In doing so, we differentiate between the transfer pricing that is mandatory under commercial law, i.e. the business mapping of deliveries and services, and the testing required by tax law (so-called OECD transfer pricing methods) along the transfer pricing methods that the OECD recommends to nation states and their financial authorities for the assessment of transfer pricing and / or profit distribution.

We equip the GTP® models of the adequacy analysis with the necessary external comparison information; several database systems and benchmark concepts are used for this. Third-party comparisons relate, for example, to profitability and cost indicators, license indicators, interest rates or monetary price information. Other relations and information can also be used.