BEPS | Transfer pricing



Cross-border business transactions with related parties have to be established in accordance with the internationally accepted arm’s-length-principle and must be documented in line with domestic tax rules. Only if transfer pricing is understood as a continuous process will the taxpayer be able to minimize the related tax risks in the long run without putting their business model – as a base of corporate success – into question.


Transfer pricing has developed to a task of continuous risk management and control, whereas for compliance obligations, such as the preparation of documentation, cost and process efficient approaches are available in the meantime. 
Your business model constitutes the starting point of any transfer price setting. Our consulting approach is marked by the objective to support you in the implementation of your business ideas and goals. 
Based on our long-term experience in transfer pricing, both within Germany and abroad, we support you in the design of operative efficient transfer pricing structures as well as in the reduction of tax-related risks. 
Insofar, the business area Transfer Pricing of Rödl & Partner has been strengthened on an international level by more than 80 transfer pricing specialists in more than 32 countries.

International Presence – Rödl & Partner Transfer Pricing Group

Our strength – your benefit: More than 80 transfer pricing professionals in more than 30 countries


Booklet ”International Transfer Prices – A compact guide for companies”

transfer-pricing-roedl-partner-booklet.png The booklet "International Transfer Prices – A compact guide for companies" can be ordered free of charge from Rödl & Partner. Please send an e-mail to On request, we will gladly provide you with more information on transfer pricing and how we can best accompany your project.



Our services

We advise and support you with our industry expertise in the development of a transfer pricing strategy tailored to your business. Our services include the entire spectrum of transfer pricing advice and, in such context, in particular:

Planning, creation and implementation

  • Analysis of the existing transfer pricing systems under risk considerations
  • Development of a transfer pricing system concept and choosing a method
  • Implementation of transfer pricing systems in tax and legal terms
  • Establishment of group-wide transfer pricing guidelines
  • Consideration of related tax issues (e.g. questions about staff posting, permanent establishments or customs)
  • Support in (national) special topics (e.g. business restructurings, national regulations against BEPS)


Documentation & Country-by-Country reporting

  • National coordination of transfer price documentation
  • International documentation concepts (e.g. OECD Masterfile-Concept)
  • Creation, conversion and analysis of Country-by-Country Reports
  • Creation of Benchmark and database analyses
  • Annual financial updates of benchmark and database studies
  • Secure collaboration: Own SharePoint solution to support the creation process with operation in our own data center in Frankfurt a. M., also mobil accessible via our RDoX app


Audit & Dispute Resolution

  • Identification of transfer pricing risks (”stress tests”)
  • Support of domestic and foreign tax audits
  • Modification and adaption of documentation as well as information filters considering auditor requests
  • Preparation of transfer pricing representatives
  • Advice in issues related to appeal proceedings
  • Support in arbitration proceedings
  • Support in mutual agreement procedures
  • Consulting in APA (Advanced Pricing Agreements)


Special topics

  • Transfer of functions
  • Permanent establishments
  • Employee secondment
  • Cost allocation systems
  • Financing
  • Valuation of intangible assets
  • Determination of licenses
  • Determination of interest rates
  • Transfer pricing-due diligence
  • Structure of an operative transfer pricing management
  • Quick and easy collection and analysis of data – collaborative implementation of an  ongoing transfer pricing risk analysis with our BI / Analytics team from Rödl IT Consulting


BEPS: OECD/G20 project against Base Erosion and Profit Shifting Project

On 5th October 2015, after more than two years of work, the OECD released the final package against ”Base Erosion and Profit Shifting” (BEPS). The initiative between the OECD and the G20 members was formed as a reaction to an increase in fiscal challenges that governments have been faced with. Some final outcomes of the BEPS project with special regard to transfer pricing are summarized in the following articles:

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