Transfer pricing and transfer of function and risk within business restructuring (package rules)

More and more multinational associated companies and their permanent foreign establishments are involved in bilateral international transactions.

These internal deliveries of goods and services from Germany to abroad and vise versa (within EC or to all other nations) are often viewed by the fiscal authorities of involved nations as a possible act of reallocation of taxable income.

Therefore, increasingly elaborate rules have been established which prescribe the documentation of activities to prevent or identify and calculate the amount of reallocated earnings. The compliance to these rules has become a priority focus of tax audits. We support small and medium sized enterprises and company-groups with:

•  analysis and documentation of function and risk
   allocation according to § 1 AStG
•  transfer price documentation according to the arm’s length principle
•  conceptualization of businessrestructuring and transferring of entrepreneurial
    function-/risk packages
•  advice on the taxation effects at the level or your German activities (permanent
   establishment, partnership, corporation) from mergers