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.


Our services

Rödl & Partner‘s transfer pricing division supports its international clients worldwide in the individual structuring, documentation and defence of cross-border business relationships within the company group. We work closely together across all business areas. Based on the market requirements, we staff the teams in such a way that they can achieve the client‘s goals successfully.


Rödl & Partner has many years of experience in supporting multinational enterprises in the field of transfer pricing. Together with our international colleagues in over 100 own locations, we can advise you in the following areas, by closely coordinating with our teams across borders:


 In focus: Global Approach and TP Factory

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Digitalisation is fundamentally changing our working world. No tax department can evade it. With the Global Approach and the TP Factory, Rödl & Partner already offers the possibility to fundamentally change the way transfer pricing documentation is created. More »

 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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