© 2021: Schlecht und Partner

International transfer pricing:

Strategies, optimization and documentation

International transfer pricing:

Transfer pricing (also known as intercompany pricing or transfer pricing) is particularly significant for international companies.

Although cross-border transactions of goods and services between affiliated companies dominate the business operations of medium-sized companies in today's globalized world, the tax implications are often overlooked—often with very significant adverse consequences for the affected companies.

Incorrect or improperly documented transfer prices can lead to very unpleasant consequences in Germany as well as abroad. Tax back payments due to estimates by the tax authorities, the reversal of the burden of proof, or high interest rates on back taxes for previous years are often the result of a failed or neglected determination and documentation of transfer prices.

We are here for you:

Transfer pricing is increasingly becoming the focus of tax audits and thus represents a significant risk factor. We help you avoid these risks

Audit of transfer prices by tax authorities

In Germany, since the introduction of principles for the documentation of cross-border transfer prices, transfer pricing-related issues have been a prominent and increasing focus of tax audits for internationally active companies.

Initially, mainly large multinational corporate groups were thoroughly audited regarding transfer prices, but now medium-sized companies with their cross-border activities are increasingly under the scrutiny of tax authorities. Faulty transfer pricing systems or inadequate documentation regularly lead to significant negative consequences.

Thus, domestic and foreign tax audits first analyze possible formal defects in the transfer pricing documentation, including the functional and risk analysis of internationally active companies. In a second step, the appropriateness of the agreed transfer prices is then examined.

Foreign tax authorities are also increasingly focusing on transfer prices, and most countries have now implemented regulations for documenting transfer prices, with transfer pricing issues increasingly taking center stage during foreign audits.

Do you need advice on transfer pricing?

Contact us!

We support you in the area of transfer pricing.

"Transfer pricing is increasingly becoming the focus of tax audits and thus represents a significant risk factor. We help you avoid these risks."


To avoid these disadvantages, companies that exchange goods or services with affiliated companies across borders should ensure that these are appropriately priced and necessary documentation is created.

Furthermore, ideally, a robust and audit-proof transfer pricing strategy should be chosen and implemented before the actual cross-border transaction takes place. We are happy to assist in this regard and discuss various scenarios with you.

As long-standing experts in international tax law, we are happy to support you. Our support does not end at the borders of Germany, which is especially crucial in the area of transfer pricing. Cross-border situations must be viewed and assessed from the perspectives of all involved jurisdictions to avert negative consequences for the entire corporate group. Our multilingual team is happy to help you address your concerns abroad with the support of foreign experts.

As a founding member of the international network XLNC, we have established contacts with experienced consultants in almost all countries.

Transfer pricing.
Our range of service.

Our experienced experts comprehensively and competently support you with your domestic and foreign transfer pricing and documentation obligations. In doing so, we analyze the current situation and develop appropriate recommendations for action based on this to establish a solid transfer pricing system and the necessary documentation.

Our service range in the field of transfer pricing is multifaceted and can be adapted to the respective needs and circumstances.

Our Service offering:

  • Efficient identification of transfer pricing risks and optimization potential
  • Creation and updating of database studies to determine arm's length transfer prices
  • Review and analysis of existing structures, demonstration of optimization approaches as well as clarification of possible tax risks and presentation of strategies to minimize or avoid risks
  • Review of the appropriate pricing of intra-group loans or financing
  • Identification of tax risks existing at home and abroad that arise from supply and service relationships between affiliated companies

Your advantages

  • Efficient determination of the current status identification and any transfer pricing risks
  • Basic basis for deriving individual solutions to reduce existing risks
  • Support in the conception and implementation of transfer pricing systems
  • Creation and updating of transfer pricing documentation
  • Check whether existing transfer pricing documentation complies with the applicable legal regulations at home and abroad
  • Creation of clear functional and risk structures as well as standardization of intercompany transactions
  • Analysis of the consequences of cross-border relocation of functions abroad
  • Legally secure relocation of functions and business opportunities
  • Identification of possibilities for designing cross-border value chains
  • Creation/support in the development of intra-group delivery, service, allocation, license agreements, etc.
  • Coordination of cross-border transfer pricing issues in collaboration with foreign consultants

Your advantages

  • Optimization of transfer pricing systems
  • Reduction of compliance costs
  • Avoiding the vulnerability of the transfer pricing system in the context of domestic and foreign tax audits
  • Support in the assessment and documentation of transfer pricing issues that have already been implemented
  • Creation of complete or partial transfer pricing documentation with functional and risk analysis based on tried-and-tested concepts and analysis tools
  • Support with the timely, professional and secure documentation of transfer prices in the company (transfer pricing management)
  • Joint coordination and implementation of efficient and individual documentation models in accordance with the applicable legal requirements (centralized documentation approaches, master/local file or country-by-country report, etc.)
  • Conversion of existing transfer pricing documentation to the master file/local file approach that will apply from 2017
  • Implementation of CbC reporting and the corresponding CbC messages
  • Creation of bilingual transfer pricing documentation (German/English) for effective communication within the group of companies

Your advantages

  • Time and cost savings by developing transfer pricing documentation, tailor-made for your company
  • Reduction of compliance costs
  • Avoiding risks from inadequate documentation
  • Meeting legal documentation requirements and avoiding the vulnerability of the transfer pricing system in the context of domestic and foreign tax audits
  • Adjustable services depending on your needs
  • Representation of transfer prices, transfer pricing systems and transfer pricing documentation in tax audits and foreign audits
  • Support with tax audits and mutual agreement procedures at home and abroad
  • Support in legal proceedings

Your advantages

  • Our experts have many years of experience in tax audits
  • Adjustable services depending on your needs

Consultant for consultants.
Collegial support.

We have been supporting professional colleagues in specialized questions of international tax law and other tax law areas for years. In doing so, the protection of the mandate is at the center of our consulting service.

We act on your behalf or for your clients in specific individual cases or projects defined in advance by you. It is up to you and your clients to decide whether to disclose their data to us or have us handle the case abstractly. For us, the confidentiality and protection of your mandate is the highest priority.


We are your competent partner in an international enviroment

Our focus in international tax law is based on years of experience in actively advising companies operating across borders. Our multilingual consultants have an extraordinary and continuously expanding expertise, including qualifications as specialists in international tax law, thus demonstrating their special expertise in the field of cross-border tax advice.

Numerous professional publications further evidence the professional orientation of our colleagues and firm.


Together we create added value

We are happy to support you!

Our expert team is multilingual and intercultural. In time-critical projects, fixed contact persons pragmatically and on schedule issue clear recommendations and risk assessments.

Your benefit? Efficient and successful consulting.

Dr. Benjamin Cortez

Dr. Benjamin Cortez

Certified Tax Advisor
MBA (International Taxation) LL.M. (corp. restruc.)

Social Media

Michael Schlecht

Certified Auditor
Certified Tax Advisor

Social Media

Andreas Lang

Andreas Lang

Expert Transfer Pricing

Social Media