Transfer pricing is one of the most complex and heavily scrutinized areas of international tax.
Our global team helps clients navigate this evolving landscape with clear, practical advice tailored to your commercial objectives and operating model.
We offer end-to-end support across the transfer pricing lifecycle—from policy design and documentation to audits, APAs, and litigation. Our tax professionals and economists work seamlessly across jurisdictions, combining legal and economic insight to manage risk and meet compliance requirements.
Clients across industries—including financial services, insurance, technology, consumer products, and life sciences—turn to us for our ability to align tax strategy with real-world operations. We collaborate closely with in-house teams, regulators, and local advisors to deliver consistent, defensible outcomes around the world.
Why do clients trust us for transfer pricing matters?
- Tailored transfer pricing policies aligned with your business model and financial goals
- Integrated support across structuring, documentation, controversy, and resolution
- Strong working relationships with tax authorities in APAs and mutual agreement procedures
- Seamless coordination across the US, Europe, and key global markets
- Deep experience in dispute resolution, including litigation and cross-border defense
What transfer pricing services do we offer?
- Designing policies for global reorganizations and post-M&A integration
- Structuring IP and principal models (DEMPE), including valuation and intercompany arrangements
- Preparing intercompany agreements across licensing, technology, services, and finance
- Advising on permanent establishment profit allocation for financial services clients
- Managing transfer pricing audits, appeals, and compliance with master/local file and CbCR requirements
Our transfer pricing services encompass a wide range of solutions tailored to meet the needs of various industries. Our experience includes:
- Advising start-ups and industrials on their expansion into the US market, including dual supply chain models for Europe and the US.
- Providing transfer pricing documentation, valuation, and benchmarking services, having completed more than 200 documentation projects.
- Structuring over 100 principal and IP holding structures for Development, Enhancement, Maintenance, Protection, and Exploitation (DEMPE) for start-ups, industrials, and technology, media, and telecommunications clients.
- Designing and implementing transfer pricing and IP (holding) business models, including valuation and documentation.
- Preparing intercompany license arrangements and determining arm’s length royalties for patents, trademarks, software, and technology know-how.
- Leading mutual agreement procedures and advance pricing agreements for clients in financial services, insurance, technology, media, telecommunications, retail, and hospitality sectors.
- Representing clients in over 70 transfer pricing-related tax court proceedings across all jurisdictions in Europe, the UK, and the US.
- Project leading simultaneous administrative appeal proceedings for 80 different taxpayers.
The OECD has proclaimed the century of transparency and cooperation between taxpayers and the tax administration. It is pivotal for any taxpayer to understand their legal rights and duties to develop a robust transfer pricing position in audit.
Head of Tax, Germany