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
Contacts
Dr. Lars H. Haverkamp, LL.M. (Christchurch)
Partner
Dusseldorf, Allemagne
David B. Blair
Partner
Washington, DC, États-Unis d'Amérique
Robert Waterson
Partner
Londres, Royaume-Uni
Rafael Moll de Alba
Partner
Luxembourg, Luxembourg
Gianluca Nemec
Partner
Milan, Italy
Caroline C. Setliffe
Partner
Washington, DC, États-Unis d'Amérique
David J. Fischer
Partner
Washington, DC, États-Unis d'Amérique