We offer consulting services for all questions in regards to transfer pricing. Applying the arm’s length principle in a pragmatic and creative way is what characterizes our services. Compliance with the arm’s length principle will be ensured by aligning your business processes with your transfer pricing system.
Design and optimization of transfer pricing systems
- Gaining a sound understanding of your business model is the starting point for our consulting services. We do not trade in one-size-fits-all type of solutions, but rather strive to support you in performing targeted improvements to your existing system.
- Minimizing tax related risks must not infringe with your business processes. A sustainable transfer pricing system needs to harmonize processes between tax, controlling and accounting.
Supporting transfer pricing documentation
- Identification and implementation of customized documentation strategies.
- Optimizing documentation processes and rendering support services in compiling master- and local files.
- Supporting updates and modifications to economic analyses and documentations regards to the post-BEPS regulatory environment on the international level (OECD and EU) as well as on the national level (Germany).
Consulting for special transfer pricing issues and extraordinary transactions
- Business relocations (transfer of functions)
- Valuation of intangibles (DEMPE Analysis, Benchmarking)
- Cost Allocations and Pool Agreements
- Permanent Establishments
- Value chain analysis
- Arm’s length profit margins and cost surcharges (Benchmarking as well as utilization of internal comparables)
- License and franchise agreements
- Loans and Cash Pooling
Consulting for consultants
TP&C supports smaller and mid-level tax advisory and audit firms in rendering high quality transfer pricing services to their clients. As highly specialized consultants, we are the ideal partner for smaller advisory firms. We do not offer tax advisory and thus pose absolutely no threat for smaller firms in terms of protecting their client relationship. In conducting joint projects we put a lot of emphasis on teamplay and guarantee a proactive communication.
TP Tools und Workshops
Flat fees for standardized services
Our consulting services are always tailored to the idiosyncratic requirements of your business processes. Some services, however, exhibit a comparatively high degree of standardization. In order to ensure a transparent and fair pricing structure, we want to offer you flat fees for these services.
Benchmarking (Amadeus/Orbis) - arm's length profit margins
5.500 €* + (10 € * x)
As a kick-off to each benchmark study we consult you in regards to calibrating the search strategy in order to ensure a best fit to the tested transaction. The quality of benchmark studies crucially depends on an appropriate ‘manual screening’* procedure of the comparables (companies or license agreements). In order to ensure the high quality of the analysis, i.e. a high degree of comparability and a homogeneous composition of the final set, we apply a minimum scope to our manual review process of 120 companies or 12 license agreements respectively. For each additional company an additional fee of 10 € will be applicable – or 75 € for each additional license agreement. Complementary to the benchmark report we provide you with an internal quality profile which gives an summary of the stability of the results and any particularities observed during the search process. The quality profile can be utilized as a foundation for explaining (defending) the results of the analysis.
* Please note that the basis fee (5.500 €) depends on the current agreements negotiated with the providers of the database - hence, there might be adjustments from time to time.
**Please note that we define ‘manual screening’ as actually manually reviewing the available information on comparables in the internet. Other providers count applying quantitative search criteria (i.e. financial thresholds) as ‘manual screening’ as long as these criteria are set after extraction of the data from the database – we believe that this is pretty close to cheating and disapprove of these practices. So yes, our fees are a little higher than what you might see elsewhere, but you get quality for your money.
Benchmarking (Royalty Stat, Royalty Source) - arm's length royalties
4.000 €* + (75 € * x)
* Again, please note that the basis fee (4.000 €) depends on the current agreements negotiated with the providers of the database - hence, there might be adjustments from time to time.
TP&C Benchmark and Documentation-Review
1.000 € / 1.500 € / 2000 €
For a review of your existing benchmark-studies and transfer pricing documentations, our fees are based on the volume of the respective documents. For up to 50 pages our fee is 1.000 €, between 51 and 90 pages the fees is 1.500 € and for anything over 91 pages we charge 2.000 €. We provide you with the results of our analysis in a detailed quality profile, which summarizes the identified risks and outlines specific ideas and suggestions (incl. The wording of entire paragraphs) for improving your analysis and documentation.