To minimize potential transfer pricing risks, a taxpayer must proactively plan transactions with its related parties. The taxpayer may also define its transfer pricing policies in a way that significantly reduces tax expenses.

Significant tax risks also arise in situations where services provided by one group member to another are not invoiced (so-called transfer mispricing). For example, a parent company may provide accounting services for the group, advisory services, legal services, or lease office space to a subsidiary, without charging for these services. Such practices often lead to VAT risks regarding the right to deduct input tax, risks related to the recognition of expenses in the tax balance sheet, as well as risks from the perspective of providing gifts to related parties.

Our tax experts are at your disposal to help you define transfer prices and reform your current transfer pricing policies.