Transfer pricing documentation

The international documentation requirements applicable in most countries with regard to intra-group business relationships abroad have also existed in Germany for a long time. Accordingly, business relationships involving a foreign element with related persons have to be documented without exception in terms of type and content; in the case of unusual or irregular business transactions within a narrow time frame.

As a rule, records should only be presented to the tax authorities when an external audit is performed. We strongly advise against follow-up documentation to meet such a demand, which is subject to a deadline of 60 days, or 30 days in the case of unusual or irregular business transactions. In order to be prepared for the questions and demands of the tax audit, we therefore develop complete transfer pricing documentation in good time with our clients for all intra-group trade relationships. We aim to avoid recording all individual business transactions. This we achieve through standardisation and binding definitions of transfer prices for all the existing business transactions within the group, in the form of a so-called group transfer price guideline. An obligation to record individual transactions only arises if they deviate from this generally applicable group guideline.

For large company groups (group turnover of at least €750 million), so-called country-by-country reporting (CbCR) is also required. We support you in preparing and filing the required reports.

Furthermore, we consult with our foreign partners in Kreston, a global network of medium-sized auditors and tax consultants, to ensure that the country-specific peculiarities of the foreign group company are also taken into account.