Planning and optimization of Transfer Pricing Systems:
- Assistance with the determination of appropriate transfer prices
- Analysis and adjustment of existing systems for the optimized allocation of resources and avoidance of double taxation
- Integration of different Transfer Pricing systems in case of Mergers and Acquisitions
- Preparation of credit rating analyses within the framework of thin capitalization rules
- Advice on the tax optimization of value added chains
- Simulation of alternative scenarios on the basis of Transfer Pricing models (financial modelling)
Documentation of Transfer Pricing systems:
- Preparation of global documentation studies pursuant to national and international guidelines (OECD, Tanzanian Transfer Pricing as per Income Tax Act 2004)
- Preparation of internal Transfer Pricing guidelines
- Enhanced awareness and coaching of employees on the topic of Transfer Pricing
- Implementation of IT-based solutions for analysis and documentation
- Documentation of the Transfer Pricing system by means of functional, risk, value added contribution and benchmark analyses
- Preparation and documentation of intercompany agreements
Advice on business restructurings and the relocation of company functions:
- Individual assessment of transfers of tangible and intangible assets
- Assistance with the evaluation of transfer packages
- Determination of the earning value of individual functions
Defence of Transfer Pricing systems:
- Defence of existing systems in external tax audits as well as in mutual agreement and arbitration procedures
- Advice and assistance in negotiations of Advance Pricing Agreements (APA)