Although the guidelines regarding transfer pricing and the arm’s length principle are governed on international level, their practical application is always based on national laws and interpretations. That is why there is always a certain amount of uncertainty involved in the taxation of a group engaged in cross-border business operations.
We help our customers remove some of that uncertainty by versatile utilization of different advance procedures including – in addition to proactive communication and traditional preliminary rulings – pre-emptive discussions (both domestic and Cross-Border Dialogue) and Advance Pricing Agreements (APA). When required, we assist in national appeal and litigation processes where we aim to bring together our juridical and financial know-how to achieve end results that are acceptable for the customer.
Once the appeal process is over, we continue to ensure that – to avoid double taxation – the required corresponding adjustments are carried out either via a mutual agreement procedure (MAP) or via arbitration.
For proactive risk management and to guarantee maximum process efficiency in managing tax-related disputes arising in different countries, we recommend our innovative TP|BackOffice service concept. Under this concept, we act as your trusted partner in all transfer pricing related matters and assume overall responsibility for the agreed tasks in a cost efficient manner.