Transfer Pricing

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Internationally active companies must define and document transfer prices for cross-border intragroup transactions. Tax authorities around the world are increasingly scrutinizing these prices, as they have a direct impact on the tax base in each jurisdiction.
Deficient or insufficiently documented transfer pricing systems can lead to tax adjustments, double taxation, and penalties. At the same time, companies must ensure that their transfer pricing structures not only comply with tax regulations but are also economically sound and operationally feasible.


Tailored Transfer Pricing Concepts for Your Company
Our transfer pricing experts support you in developing a defensible and tax-optimized structure for your intragroup transactions. We create practical, business-oriented solutions that ensure compliance with legal requirements and minimize tax risks.
Our Services in Detail
- Preparation of functional analyses
- Development of transaction matrices
- Structuring of cross-border financing arrangements
- Review of existing transfer pricing policies for compliance and potential improvements
- Alignment of transfer pricing systems with international regulatory requirements
- Preparation of legally compliant Master Files and Local Files in accordance with BEPS (OECD) standards
- Support in meeting country-specific documentation requirements
- Implementation of an efficient documentation framework to avoid tax disputes
- Drafting of intercompany agreements for cross-border services
- Assistance with tax audits focusing on transfer pricing issues
- Negotiations with tax authorities to reduce potential adjustments
- Use of mutual agreement procedures and Advance Pricing Agreements (APAs) to prevent future risks
Your Benefits
- A single point of contact at Auren for coordinating all services
- Legal certainty and tax compliance through defensible transfer pricing structures that prevent tax disputes
- Minimisation of tax risks through transparent and documented systems that reduce exposure to reassessments, double taxation, and penalties
- Business-oriented solutions that integrate transfer pricing into your overall business model for operational efficiency
- International expertise from a single source – global advisory service with in-depth local knowledge for a tax-optimized structure
