Michael Scharf

Phone: +49 (9 11) 91 93 - 10 70
Fax: +49 (9 11) 91 93 - 70 70

Dr. Kai-Uwe Bandtel

Phone: +49 (89) 92 87 80 - 560
Fax: +49 (89) 92 87 80 - 860

Cross-border business transactions with related parties have to be established in accord-ance with the internationally accepted arm’s-length-principle and must be documented in line with domestic tax rules. Only if transfer pricing is understood as a continuous process, the taxpayer will be able to minimize the related tax risks in the long run without putting his business model – as a base of corporate success – into question.

Transfer pricing has developed to a task of continuous risk management and control, whereas for compliance obligations, such as the preparation of documentation, cost and process efficient approaches are available in the meantime.

Your business model constitutes the starting point of any transfer price setting. Our consulting approach is marked by the objective to support you in the implementation of your business ideas and goals.

Based on our long-term experience in transfer pricing, both within Germany and abroad, we support you in the design of operative efficient transfer pricing structures as well as in the reduction of tax related risks.

Insofar, the business area Transfer Pricing of Rödl & Partner has been strengthened on an international level by more than 80 transfer pricing specialists in more than 32 countries.

International Presence – Rödl & Partner Transfer Pricing Group

Our strength – your benefit: More than 60 transfer pricing professionals in more than 30 countries

Booklet "International Transfer Prices – A compact guide for companies"

The booklet can be ordered free of charge from Rödl & Partner. Please send an e-mail to margit.pouget‎@‎ with the subject line “I would like to order the booklet International Transfer Prices – A compact guide for companies”.

On request, we will gladly provide you with more information on transfer pricing and how we can best accompany your project.

Take a look into the booklet »

Our Services

We advise and support you with our industry expertise in the development of a transfer pricing strategy tailored to your business.

Our services include the entire spectrum of transfer pricing advice and, in such context, in particular:


  • Analysis of existing transfer pricing systems under risk considerations
  • Development of transfer pricing systems
  • Design and implementation of transfer pricing guide-lines
  • Selection and application of appropriate transfer pric-ing methods according to national and international transfer pricing standards
  • Preparation of comparables
  • Preparation of database and benchmark analyses


  • Preparation of transfer pricing documentation for domestic and foreign tax requirements
  • Review of existing documentation
  • Functional and risk analysis
  • Analysis of value chains
  • National and international coordination of documentation
  • Verification of profitability
  • Development of coordinated documentation processes


  • Support of domestic and foreign tax audits 
  • Risk analysis of existing documentation
  • Modification and adaption of documentation as well as information filters considering auditor requests
  • Preparation of transfer pricing representatives
  • Advice in issues related to appeal proceedings
  • Support in arbitration proceedings and mutual agreement procedures
  • Advice in APA (Advanced Pricing Agreements)

Special Topics

  • Transfer of functions
  • Permanent establishments
  • Employee secondment
  • Cost allocation systems
  • Transfer of assets
  • Valuation of intangible assets
  • Transfer pricing-due diligence

BEPS: OECD/G20 project against Base Erosion and Profit Shifting Project

On 5th October 2015, after more than two years of work, the OECD released the final package against ”Base Erosion and Profit Shifting” (BEPS). The initiative between the OECD and the G20 members was formed as a reaction to an increase in fiscal challenges that governments have been faced with.

Some final outcomes of the BEPS project with special regard to transfer pricing are summarized in the following articles: