Transfer prices and the related potential for profits shifting to foreign countries with lower tax rates are increasingly coming under scrutiny of tax authorities under the banner of the “base erosion and profit shifting” initiative of the OECD ("BEPS"). Failure to give sufficient attention to the importance of intangible assets often results in later tax adjustments.
If the comprehensive transfer pricing documentation requirements are not considered this can result in considerable penalties for multinational enterprises. Transfer pricing risk management projects allow the corresponding transfer pricing risks to be identified, assessed and minimized. With adequate value chain planning transfer prices can be planned and optimized, e. g. in the context of the implementation of principal structures, centralized services or the reorganization of distribution structures. At BDO we assist companies with the relevant documentation, TP risk management systems and value chain planning. We also help our clients defend their transfer prices in audits, before fiscal courts, in mutual agreement and arbitration procedures, when making binding rulings and when entering into advanced pricing agreements.