Analysis

Analysis

Arm’s Length Assessment, Income Allocation and Defense Positioning

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Documentation

Documentation

Evidence and
Tax Compliance

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Project Organisation

Project Organisation

Transfer Pricing Management and
Expertise

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On Transfer Pricing Management

All business transactions between related parties, on the basis of the law of obligations. Examples are:

  • Product deliveries
  • Management services and support services
  • Financial services
  • Rights to use tangible or intangible assets and other licensing transactions
  • Employee secondments
  • Restructuring projects

 

 


Demand from the Market

The GTP® MANAGER consists of components of a overall transfer pricing management solution for multinational groups. Supervision, analysis, arm’s length data, coordination, administration, and documentation of transfer prices, compliance management.

 

 

 

 

 


Objectives of Transfer Pricing Management

  • Setup and optimization of business transactions within the multinational group (law of obligations)
  • Differentiation and coordination with shareholder exchanges (corp. law)
  • Efficient governance and administration of IC business relationships
  • Production and administration of tax-law transfer pricing documentation for each related-party unit and the multinational group
  • Compliance and sustainable corporate governance

 


Today’s Challenges behind Transfer Pricing Management

  • Usage and audit of compliance management systems
  • Arm’s length assessment for situations of domestic permanent losses and excess profitability abroad
  • Group-wide realization of the OECD/BEPS documentation models referring to Masterfile and Countryfile Reporting
  • Transfer pricing team-building with experts from group departments, external consultants, and national and international tax officials
  • Training and knowledge management in volatile team bodies and internationally coordinated groups
  • Digitalization of business processes and cross-boundary management of data and documents
  • Deployment of, and consistency with information stored in data systems of the group