Transfer Pricing

This book presents the complex area of transfer pricing in a clear and structured way by means of a case study. The case study involves cross-border transactions of a fictive company group. Every chapter includes specific aspects relating to the initial case. The authors base the case-solving on OECD Transfer Pricing Guidelines for Multinational Enterprises with multiple references made to German tax law. It is the aim of the book to introduce beginners in to the basics of transfer prices for tax purposes. In principle everything could be reduced to a globally unified standard: the arm‘s length principle.

The book grants the reader an entertaining, practical and structured introduction into the world of transfer pricing giving the necessary orientation and at the same time raising awareness which can also be supportive for advanced practitioners.

Table of Contents:

1. Introduction – the arm’s length principle

2. The first step: Value Chain Analysis

3. Transfer Pricing Methods

4. Comparability Analysis

5. Supply of materials

6. Intangibles

7. Services

8. Cost Sharing Arrangements

9. Cost Contribution Arrangements

10. Business restructuring/transfer of functions

11. Financial Transactions

12. Tax challenges arising from the digitalisation of the economy

13. Permanent Establishments

14. Obligation to cooperate – Transfer pricing documentation

15. Country-by-Country Reporting

16. Litigation, dispute avoidance and resolution