Transfer pricing check and risk analysis
Where are your transfer prices sound – and where is action needed? We examine structures, methods, documentation, and intra-group contracts. You will receive a risk assessment with a traffic light report and a prioritized action plan.
Fixed price €2.900 practice-oriented structured OECD-compliant
When should the TPC be integrated?
Intra-group deliveries, services, licenses or financing have existed for years, but have not yet been systematically checked for consistency and arm's length principles.
New foreign subsidiaries, new markets or additional intra-group transactions change the requirements for structure, contracts and documentation.
Functions, risks, decision-making processes or value creation contributions have shifted, while the existing transfer pricing model has remained unchanged.
You want to identify and fix weaknesses before the tax authorities request data, contracts, transaction matrices, or documentation.
A new CFO, Head of Tax, commercial director or tax advisor quickly needs a reliable overall picture of the existing transfer pricing situation.
Individual questions regarding margins, markups, contracts, or documentation requirements are known, but an overarching assessment and prioritization is lacking.
These topics are of interest
many of our clients.
We cannot currently assess with certainty whether our internal group prices and margins are at arm's length.
Our contracts, calculations, and transfer pricing documentation are not fully aligned.
We want to know which issues are truly critical and which can initially be resolved pragmatically.
We need a structured entry point without immediately triggering a large-scale documentation or design project.
We want to consider transfer prices from the perspective of the company, the consultant, and a subsequent tax audit simultaneously.
Our compliance check in five steps
- 1Kick-off meeting
A personal meeting and joint coordination of the next steps. We understand your business model and your specific requirements. - 2Questionnaire & Document Request
We will send you a structured questionnaire and a detailed document request, tailored to your company structure. - 3Analysis & Review
Careful review and in-depth analysis of the submitted documents by our experienced transfer pricing experts. - 4Action required & recommendations
Identification of optimization potential and development of concrete recommendations to improve your transfer pricing compliance. - 5Results Workshop
Discussion of the results of the initial analysis of your transfer pricing landscape within the framework of a joint workshop with a concrete action plan.
Your benefits at a glance
For more than ten years, we have been advising medium-sized companies and multinational corporations on the selection, implementation, and defense of transfer pricing structures. Our team combines transfer pricing expertise with decades of experience in sustainable tax planning and compliance.
With our many years of experience and market proximity, we translate the complexity of transfer pricing requirements into clear, audit-proof structures. Because: Tax follows business – and your compliance should follow your business model.
What you can expect from our compliance check
Identification of compliance gaps and potential tax risks in your existing transfer pricing structure.
Review of your existing documentation for completeness and compliance with current legal requirements.
Assessment of the appropriateness of your transfer prices based on the arm's length principle and common methods.
Concrete, practical measures to optimize your transfer pricing structure and documentation.
Preparation for tax audits and strengthening your position vis-à-vis the tax authorities.
Consideration of international standards such as OECD TP guidelines and EU requirements.
Why choose TPC as your partner?
Experienced team of experts
Over 10 years of experience in transfer pricing consulting – on both the consultant and client sides. Our team combines expertise in tax, business administration, and law.
Boutique approach
Direct contact person, high availability, efficient processes. Professional excellence from the Big 4 combined with practical and cost-effective consulting.
Focus on SMEs
Specializing in the needs of medium-sized companies and internationally oriented family businesses.
Practical solutions
No theoretical concepts, but actionable strategies that work in practice and can be defended.
Frequently asked questions
Answers to the most important questions about the Transfer Pricing Compliance Check
How does the Transfer Pricing Compliance Check help to improve the existing transfer pricing system?
The Transfer Pricing Compliance Check reveals whether the existing transfer pricing landscape still aligns with actual value creation and the distribution of functions and risks within the group. The focus is not on individual errors, but rather on whether compensation models, contracts, documentation, and actual implementation present a consistent overall picture.
For example, optimization may be necessary if business models, responsibilities, or intra-group transactions have changed over time, but the transfer pricing system has not been adjusted accordingly. The same applies if companies assume functions or risks without being adequately compensated, or if existing pricing logics are unnecessarily complex and difficult to implement operationally.
Based on this foundation, areas for action are prioritized and concrete recommendations for a robust transfer pricing model are developed. The goal is an economically sound, practical, and documentable structure in which intra-group compensation aligns with the functional and risk analysis. This creates a sustainable foundation for ongoing service allocation, transfer pricing documentation, and future tax audits.
Yes, a transfer pricing compliance check is particularly advisable after an upcoming tax audit. The transfer pricing check quickly identifies which intra-group transactions require immediate attention. Typical risks identified during tax audits include incomplete transfer pricing documentation, missing contracts, outdated fairness analyses, or discrepancies between transfer pricing documentation and actual implementation.
Based on this foundation, documents can be supplemented in a targeted manner, lines of argument prepared, and critical issues assessed in advance. The aim is not to rework all topics, but to prioritize the key transfer pricing risks and to prepare the company in a structured way for questions arising during a tax audit.
For the Transfer Pricing Compliance Check, we primarily require existing documentation relating to your intra-group business relationships. This typically includes existing transfer pricing documentation, intra-group contracts, annual financial statements, transaction summaries, transfer pricing policies, and any existing appropriateness analyses. The specific documents required depend on your company structure and the relevant transactions.
The internal effort required from your tax and finance department typically remains manageable. At the outset, you will receive a structured questionnaire and a targeted document request. This ensures clarity from the beginning regarding the necessary information. Beyond the kick-off meeting and the results workshop, only occasional follow-up questions usually arise. We handle the technical analysis, risk assessment, and prioritization of necessary actions. This allows you to gain a reliable overview of potential documentation gaps and transfer pricing risks with reasonable internal effort.
A transfer pricing compliance check is a structured inventory of cross-border business relationships with related or associated parties. The review focuses particularly on the supply of goods, services, licenses, loans, guarantees, and cost allocations. We compare functional and risk profiles, contracts, actual implementation, transfer pricing methods, evidence of appropriateness, and transfer pricing documentation. Additionally, we examine the transaction matrix, data availability, responsibilities, and operational pricing processes. The results for each area reveal which structures are robust, where risks exist according to Section 1 of the German Foreign Tax Act (AStG) or Section 90 Paragraph 3 of the German Fiscal Code (AO), and which measures should be implemented and in what order.
A compliance check is advisable as soon as a company maintains cross-border supply or service relationships with affiliated companies, shareholders, or other related parties. It is particularly recommended before a tax audit, in the case of initial international expansion, significant growth, acquisitions, restructurings, new financing or licensing models, and when transfer prices have not been updated for an extended period.
Typical warning signs include missing contracts, persistent losses in individual companies, unexplained management fees, high loan volumes, or discrepancies between the contract, documentation, and actual practice. This check provides clarity early on, before short deadlines or audit requests restrict the available options.
The check is typically carried out in five steps:
(1) Kick-off and delimitation of the relevant companies and transactions,
(2) structured data and document requirements,
(3) Interviews with tax, finance and specialist departments,
(4) technical analysis and risk assessment as well as
(5) Results workshop with prioritized action plan.
Organizational charts, transaction overviews, contracts, transfer pricing documentation, calculations, benchmarking studies, annual financial statements, and process descriptions are regularly required. The scope and depth are tailored to the size, countries involved, transaction types, and risk profile. With readily available documentation, the inventory can often be completed within a few weeks.
You will receive a transparent assessment of your transfer pricing landscape, including findings, risk classification, and concrete next steps. Typical results include an overview of missing or outdated documents, inconsistencies between contracts and practice, weaknesses in price determination, and process and data gaps. The measures are prioritized according to urgency, tax risk, and implementation effort, and can include assigned responsibilities and target dates.
This provides management with a reliable basis for decision-making: What needs to be rectified in the short term before an audit, what should be implemented in the current year, and which topics can be integrated into the regular compliance routine?
Yes. Upon request, we will implement the prioritized measures together with your tax, finance, and legal departments, as well as your current tax advisor. This may include updating the local file, master file, and transaction matrix; preparing appropriateness assessments; professionally revising intra-group contracts; adjusting pricing calculations; and establishing robust processes and responsibilities.
We separate short-term risk mitigation measures from structural improvements and align the scope with your resources. This transforms the initial assessment into an actionable roadmap, without necessarily having to start all work packages simultaneously.
Transfer pricing documentation describes and justifies specific business relationships and transfer prices for a given documentation period. The compliance check is broader: it additionally examines whether contracts, actual implementation, price calculation, evidence of appropriateness, data flows, responsibilities, and documentation as a whole are consistent. Therefore, the check does not automatically replace a local file or master file. Rather, it reveals which documents are already usable, which gaps exist, and whether the underlying transfer pricing system is robust.
The standardized transfer pricing check costs €2.900 net for the defined scope (up to eight companies and twelve transaction types). You will receive a traffic light report, an action plan, and a closing meeting. The timeline depends primarily on the completeness of the documentation provided. For larger scopes or additional analyses, we will agree on the scope of services and fees with you in advance. You can find all the details on the [website/document/etc.]. Page for fixed price check.
How can we help you?
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