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Rödl & Partner opens new office in Waterloo, Canada |

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Transfer Pricing

Digitalization is radically changing the way we work. No tax department can avoid it.

The most efficient approach to implementing digitalization is through automating recurring and standardized processes. With the Global Approach and the TP Factory, Rödl & Partner already offers the possibility to radically change the way transfer pricing documentation is created.

With a client base largely composed of companies belonging to multinational groups, Rödl & Partner has created a Transfer Pricing Service Line with specialists in transfer pricing active in over 30 countries.

Through the Transfer Pricing Service Line, we provide tailored, global support to clients operating internationally, both in structuring, documenting, and defending cross-border transactions, as well as in other issues related to transfer pricing (e.g., Patent Box, intangible asset valuation, and permanent establishment issues).

A transnational coordination on transfer pricing concepts and values relating to the arm's length principle is essential to enhance the security of transfer pricing systems. For this reason, we closely collaborate with colleagues worldwide. Additionally, we actively monitor local and international developments and participate in their formulation.

In this context, the OECD/G20 initiative against "Base Erosion and Profit Shifting" (BEPS) is currently one of the most significant developments in international tax law. Of the 15 agreed Actions, no less than five (Action 7, 8, 9, 10, and 13) directly relate to transfer pricing, underscoring the importance of the issue for companies operating internationally.

For further information on developments and recent articles, drawn from practical experience, please refer to our BEPS-Special and TP Global Update.

OUR SERVICES

We provide consulting and support through our experience in developing a customized transfer pricing

strategy for your business.

Our services cover the entire spectrum of transfer pricing consulting, specifically:

Planning

Risk analysis of the existing transfer pricing system;
Selection and application of the appropriate transfer pricing method according to national and international transfer pricing standards;
Design and implementation of transfer pricing guidelines;
Preparation of database analyses and benchmarks;
Support regarding special issues (e.g., corporate reorganizations);
Support on related tax matters (e.g., issues related to employee secondment or permanent establishments).

Documentation

Preparation of transfer pricing documentation according to local and international standards;
Preparation of transfer pricing documentation in accordance with Action 13 BEPS;
Review of existing documentation;
Functional analysis;
Value chain analysis;
National and international coordination of documentation;
Development of a coordinated transfer pricing documentation process (Roll-Outs).

Defense

Support during tax audits;
Support in arbitration processes and Mutual Agreement Procedures (MAP);
Advanced Pricing Agreements (APA’s) (unilateral, bilateral, and multilateral).

Special issues

Corporate reorganizations;
Permanent establishments;
Employee secondment;
Cost allocation systems (CCA);
Intangible asset valuation.

contact

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Hans Röll

Head of Transfer Pricing Italy

Partner

+39 0471 1943 200

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