Partner
Certified Tax Advisor
Transfer Pricing
Transfer pricing is complex and a critical topic in corporate taxation. It's familiar territory for us, as we know the pitfalls: high correction risks, growing demands for transparency and documentation, and thus, increasing compliance effort. As a trailblazer and trusted partner, we help you maintain balance: between business and tax requirements, between complexity and compliance, between risk and efficiency. Dedicated to your success.
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Complex Transfer Pricing. Future-Proof Strategy.
We support you in all transfer pricing processes: from strategic planning and implementation to defense and protection against tax authorities. Nationally and internationally.
We create sustainable solutions tailored to your company. Always in focus: your individual transfer pricing situation. We combine in-depth expertise with a practical approach. We safely navigate you through regulatory frameworks and efficiently translate these into your corporate practice.
We keep complexity and risks under control. This results in solutions that not only work on paper but also prove effective in practice.
We identify opportunities and think ahead. Together with you, we optimize your transfer pricing processes: through standardization, automation, digitalization. Or we take over processes as a managed service.
We approach transfer pricing interdisciplinarily – not just from a tax perspective. We advise locally and act globally – as a transfer pricing team with around 200 colleagues in over 50 countries. Together, we find solutions for transfer pricing disputes, in national or international proceedings.
We shape the future. For your Transfer Pricing Compliance.
Our services
Skip SectionMaturity Analysis/Health Check
With our Health Check, we set the course for your efficient transfer pricing compliance. We analyze the maturity level of your transfer pricing processes. In doing so, we uncover optimization potential, assess tax risks, and provide guidance for the next steps – individually tailored to your company. This way, we create the conditions for a future-proof transfer pricing environment and efficient system and interface design.
Our focus areas
- Maturity analysis of your transfer pricing processes
- Identification of optimization and digitalization potential
- Qualitative assessment of tax risks
- Evaluation and design of your system landscape
- Analysis and optimization of relevant interfaces
Dr. Kai-Uwe Bandtel
Partner
Attorney at Law (Germany), Certified Tax Advisor, Specialist lawyer for tax law
Structuring & Benchmarking
Transfer prices deeply impact the corporate structure. Together, we design structures that are tax-resilient, economically sound, and internationally compatible. Together with you, we pave the way today for transfer pricing systems that will endure tomorrow. As one team, in Germany and abroad. Our benchmark studies ensure a transparent arm’s length comparison and enable the planning and subsequent defense of arm’s length compliance.
Our focus areas
- Design of tax-robust transfer pricing systems
- Selection and implementation of the appropriate transfer pricing method
- Preparation of transfer pricing policies
- Arm’s length analyses and benchmarking
- Simulation and What-if analyses
Dr. Kai-Uwe Bandtel
Partner
Attorney at Law (Germany), Certified Tax Advisor, Specialist lawyer for tax law
Documentation & CbCR
We comprehensively support international corporate groups in preparing the legally required transfer pricing documentation: whether Local Files for individual entities, a group-wide Master File, or CbCR in line with Pillar 2 requirements and Public CbCR. For German entities or with a global approach: We develop efficient and audit-proof processes to meet increasing compliance requirements and, in doing so, optimize your documentation strategy. We are ONE global transfer pricing team.
Our focus areas
- Group-wide preparation or review of transfer pricing documentation (Local Files and Master Files)
- Preparation and submission of the CbC Report, also in line with Pillar 2 and Public CbCR
- Coordination and management of local reporting obligations related to transfer pricing abroad
- Risk assessment of transfer pricing documentation including local reviews to ensure compliance
Dr. Kai-Uwe Bandtel
Partner
Attorney at Law (Germany), Certified Tax Advisor, Specialist lawyer for tax law
Defense & Protection
Transfer pricing in the focus of tax authorities? Then clarity and steadfastness are required. In tax audits, mutual agreement procedures, or in court – wherever you need us, we are there for you. Nationally and internationally. With clear recommendations, we point out new directions and solutions: regarding the arm’s length nature of your transfer prices and concerning procedural law, cooperation obligations, and burden of proof. Always forward-thinking, because a good conflict resolution today can prevent disputes tomorrow.
Our focus areas
- Tax Audits and Joint Audits
- Mutual Agreement Procedures
- Objection and Litigation Procedures
- Advanced Pricing Agreements (APA)
Dr. Kai-Uwe Bandtel
Partner
Attorney at Law (Germany), Certified Tax Advisor, Specialist lawyer for tax law
Processes & Digitalization
Effective transfer pricing management (“OTP”) efficiently translates your transfer pricing concept into operational practice. This requires clear processes, expertly trained personnel, reliable data, and tailored technological solutions. Together with you, we develop structures that work in practice. Globally, interdisciplinarily, and supported by our IT consultants. From smart tools to customized processes, we provide guidance, show the way, and secure your progress.
Our focus areas
- Establishment of efficient and practical transfer pricing processes
- Integration and optimization of data flows and ERP systems
- Use of digital tools for automation and monitoring
- Development of customized process solutions for global structures
- Interdisciplinary collaboration with IT consultants for sustainable implementation
Dr. Kai-Uwe Bandtel
Partner
Attorney at Law (Germany), Certified Tax Advisor, Specialist lawyer for tax law