10 May 2016

ADKL: A transfer pricing case study

ADKL, MSI's German multi-disciplinary member firm, offers several services for inbound and outbound cases, including transfer pricing that could support your business.

Inbound cases are important to modulate existing benchmark studies into the legal structure that is needed in Germany. ADKL offers a health check with the usual benchmarks which are used by German tax authorities on a regular basis. One of our recent projects involved the economic and tax-oriented restructure of an international operating group headed up in Germany. Our client needed an optimisation of the group's structure with the result that the group's international tax compliance level increased; the strategic controlling of all local firms was getting more efficient and last but not least the tax rate in the group decreased by using legal optimisations in the value chain. At the beginning of the project ADKL performed a detailed analysis and status report of the existing value chain. After a structured gap-analysis we created and implemented a new transfer pricing policy across the whole group along the existing value chain. At this point we worked closely with fellow member firms' colleagues of MSI Global Alliance. Later in the year we will create the annual transfer pricing documentation on a master/country file basis. All in all, those projects need a high economic knowledge of the international value chain as well as the professional support out of the MSI Global Alliance.

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