Transfer pricing for medium-sized businesses
and international corporate groups
We develop, document, and defend transfer pricing systems that fit your business model and function effectively in day-to-day operations. In doing so, we combine the requirements of the arm's length principle according to Section 1 of the German Foreign Tax Act (AStG) and the OECD Transfer Pricing Guidelines with practical processes, robust contracts, and a transparent data foundation.
Whether it's your first foreign subsidiary, an established international group, or a complex corporate structure: We support you from risk analysis through design and documentation to implementation and defense in tax audits.
Our services
Consultants for consultants
Certified Tax Advisor
Specialized support for transfer pricing issues – professionally on an equal footing, pragmatic in implementation and in partnership with your clients.
Your TPC Team
Lorenz Kurrek
"As a transfer pricing expert with experience on both the consulting and corporate sides, I help companies to design their transfer pricing structures in line with the arm's length principle and in a practical manner."
Lorenz Kurrek
Partner Transfer Pricing
Managing Director
Jeffrey Buder
"As a tax advisor with a focus on effective tax structuring, I delve deeply into business models and contribute my own experience to better solutions."
Jeffrey Buder,
Partner International Tax
Certified Tax Advisor
That's what ours say
Clients & Partners about us
Maximilian Brast
Head of Taxes
Revenue: €500-600 million
Employees: 2.200
TPC impresses with its high level of professionalism and comprehensive expertise. We particularly value the personal and collaborative partnership, characterized by sound tax knowledge and pragmatic experience. Both large and small projects are implemented in a results-oriented and responsible manner. I recommend this firm to anyone seeking a reliable partner in the areas of transfer pricing and international tax law.
• Defense of transfer pricing structures during tax audits
• Change in the transfer pricing system
• Preparation of evidence of suitability (database study)
• Preparation of transfer pricing documentation (Master File and Local File)
• Preparation of expert opinions on individual cases (e.g., regarding the establishment of a permanent establishment)
Industry
Platform-oriented technology company
(Credit, real estate, insurance)
Revenue
500-600 million euros
Employees
2.200
Andreas Jobst
Tax advisor / law firm owner
Consultants for consultants
As a tax advisor, I collaborated with TPC Transfer Pricing Compliance on a complex transfer pricing issue and am thoroughly impressed. The team demonstrates in-depth expertise, a structured approach, and consistently professional communication on equal terms. The collaboration was straightforward, goal-oriented, and extremely efficient. Technically demanding issues were presented clearly and comprehensibly, both for the client and for us as internal contacts. What was particularly positive was TPC's proactive approach, their contribution of practical solutions, and their reliable availability even for short-notice inquiries.
I can highly recommend TPC Transfer Pricing Compliance to any tax advisor and any company seeking high-quality and legally sound advice in the area of transfer pricing. We look forward to future collaborations!
Oliver Schilling
Managing Director
Revenue: €20-30 million
Employees: 10-30
Working with TPC is very pleasant and professional, both technically and personally. We particularly appreciate the short communication channels, good accessibility, reliability, and the high quality of their work.
• Support during tax audits
• (Re-)structuring of European performance relationships
• Assessment of functional shifts
• Preparation of transfer pricing documentation
Industry
Services
Revenue
20-30 million euros
Employees
10-30
Norbert Löllgen
Head of Taxes
Revenue: €500 million
Employees: 700
TPC's consulting services are consistently practical and solution-oriented. We are particularly impressed by their quick availability and their willingness to act as sparring partners. We feel confident that our issues are in good hands due to their professional expertise.
Project scope
- Development of a structure for global transfer pricing documentation
- Creation of a Master File, Local File Germany and a Local File template according to OECD guidelines
- Sparring partner on various topics, including: licensing model, service billing, financial transactions
Industry
IT hardware
Revenue
€ 500 million
Employees
700
Michael Ewald
Managing Director
Revenue: €2-10 million
Employees: 10-20
We found the collaboration with you to be extremely constructive and characterized by enormous competence.
What was particularly impressive was your ability not only to convey complex specialist knowledge at the highest level, but also to break it down in such a way that it was clearly understandable for us as the target group.
Since we are not experts in this field, the collaboration naturally couldn't take place on a purely professional level. Nevertheless, you managed to structure the exchange in such a way that it felt completely equal. This speaks to your didactic competence and your deep understanding of different target groups.
On a personal level, it was a perfect fit from the start – professional, friendly, and always a pleasure to work with. Especially in your industry, where a very matter-of-fact, almost machine-like style often prevails, this is a refreshing exception.
Therefore, I wholeheartedly recommend your services, especially for companies with international growth ambitions that lack the internal know-how to compete on equal footing. You've done a fantastic job!
Project scope
- Development of a transfer pricing system for the allocation of IP & services (licensing model)
- Value creation contribution analysis
- International corporate structure for income tax purposes
- Preparation for implementation
Industry
Sales
Revenue
2-10 million euros
Employees
10-20
Michael Klawon
Owner-Manager
Revenue: <5 million €
Employees: <10
During a tax audit, I was required to submit transfer pricing documentation for my sole proprietorship, which includes a foreign subsidiary. Initially, I attempted to find a cost-effective solution using AI. However, it quickly became apparent in practice that AI alone did not adequately meet the requirements of the German tax authorities.
Through this search, I came across Lorenz from TPC Transfer Pricing Compliance – and that was a real stroke of luck. His free template was already very helpful, but above all, Lorenz guided me confidently through the process with his pragmatic, efficient, and highly competent support. With just a few rounds of coordination, we had professional documentation that also convinced the tax authorities.
Highly recommended – thank you so much, Lorenz!
Project scope
• Support during tax audits
• Review of self-prepared transfer pricing documentation
• Substantive support in the preparation of transfer pricing documentation
Industry
Technology
Frequently Asked Questions
Transfer prices are the prices and other terms governing business transactions between related or affiliated parties. They become relevant for medium-sized enterprises (SMEs) as soon as, for example, a German company supplies goods to a foreign subsidiary, procures intra-group services, pays license fees, or receives a loan from a related company. According to Section 1 of the German Foreign Tax Act (AStG), these terms must be at arm's length, meaning they must be structured as independent third parties would have agreed upon under comparable circumstances. The decisive factor is not the size of the group, but the specific cross-border business relationship.
Typical business relationships include the supply of goods, contract manufacturing, sales services, management and IT services, cost allocations, licenses, the transfer of intangible assets, loans, guarantees, cash pooling, and restructuring. Relationships between the parent company and a foreign branch can also raise specific profit allocation issues.
For every significant transaction, the scope of services, functions, risks, assets used, remuneration, and actual execution must be analyzed. A single, general transfer pricing rule is therefore regularly insufficient for different types of transactions.
Close relationships can arise in particular through direct or indirect shareholdings, controlling influence, or special economic or personal relationships. This typically concerns parent, subsidiary, and sister companies within a corporate group. Whether a person is considered a close partner within the meaning of Section 1 Paragraph 2 of the German Foreign Tax Act (AStG) must be examined in the specific case based on the shareholdings and influence relationships. Medium-sized companies should therefore include not only formal majority shareholdings but also indirect structures and other dependencies in their transfer pricing analysis.
Non-arm's length transfer prices can lead to income adjustments, additional taxes, interest, and economic double taxation. Furthermore, missing, delayed, or unusable records may result in estimations and surcharges under Section 162 of the German Fiscal Code (AO). Operationally, additional risks often arise when contracts, transfer pricing documentation, and actual invoicing are inconsistent.
Early analysis regularly creates more room for maneuver than a subsequent defense under the short deadlines of a tax audit.
Even before the first intra-group transactions are undertaken, the business models, functions, and risks of the companies involved should be clarified. Following this, transaction types, transfer pricing methods, pricing formulas, contracts, invoicing processes, and responsibilities must be defined. Simultaneously, it should be examined which local registration, documentation, and reporting obligations apply abroad. A simple transfer pricing policy, a robust account mapping, and proportional basic documentation prevent unclear pricing processes from becoming entrenched over several years.
Yes, the arm's length principle generally applies regardless of the size of the corporate group. However, smaller companies may be eligible for simplifications regarding the type and scope of record-keeping. According to Section 6 of the German Commercial Code (HGB), these simplifications generally apply if the consideration paid for goods to related parties does not exceed €6 million and the remuneration for other services does not exceed €600.000 in the financial year. Information and existing documents must still be provided upon request. Therefore, even below these thresholds, concise documentation of transactions, contracts, and pricing is advisable.
TPC provides support in reviewing and designing transfer pricing systems, conducting appropriateness assessments and benchmarking studies, developing local files, master files, and transaction matrices, as well as in intercompany agreements and tax audits. Services range from targeted reviews of individual transactions to group-wide implementation. The focus is on practical solutions that align with the business model, available data, and internal resources. Following an initial assessment, risks, priorities, timelines, and responsibilities are clearly defined.
For an initial analysis, the group structure, a list of foreign affiliated companies and branches, an overview of cross-border transactions and volumes, as well as existing contracts and documentation, are usually sufficient. Depending on the topic, pricing calculations, annual financial statements, bank statements, benchmarking studies, loan documents, and process descriptions may also be required. It is also important to have contacts from tax, finance, controlling, treasury, and operational departments. Missing documents are not an obstacle; they will be identified and prioritized as part of the inventory process.
Yes, we are happy to work with your existing tax advisor and complement their expertise.
When companies expand their operations across national borders, issues such as international taxes and transfer pricing often become relevant. This regularly leads to a greater need for consulting services. Due to a lack of specialization, this need is often not met by the existing tax advisor. This in no way reflects on the quality of the existing tax advisor's services, but rather stems from the fact that these are extensive specialized areas. These are typically addressed by tax specialists in the market. The regulations and requirements in the area of transfer pricing are highly complex and constantly evolving. Furthermore, sound advice in the area of transfer pricing requires your advisor to possess extensive market experience. For this reason, and to avoid jeopardizing the existing relationship of trust with your tax advisor, we are pleased to offer our support.
Together with your existing tax advisor, we ensure that you operate legally compliant in the international tax environment, allowing you to fully concentrate on your business. After all, 'tax follows business,' and expanding beyond national borders is a major step for you and your company!
This success must be sustainably secured through legally compliant tax planning and adherence to compliance requirements.
What can we do for you?
Feel free to contact us – it's easy and without obligation.
