Transfer pricing

In 2016 Austria introduced statutory transfer pricing documentation requirements pertaining to intragroup and cross-border deliveries and services. Because the tax authorities examine transfer prices very closely, it has become vital for companies operating across borders to have a consistent, reliable transfer pricing system.

Efficient transfer pricing documentation greatly reduces the risk of double taxation as well as the costly and time-consuming discussions with the tax authorities involved. In addition, you can also optimize your group tax rate without forfeiting flexibility.

Our experienced specialists provide comprehensive, competent support to ensure that you meet your national and international transfer pricing and documentation requirements. We analyze the status quo in your group and propose courses of action based on our findings in order to establish a sound transfer pricing system. To this end, we take advantage of our renowned international network, which has been tried and tested in a number of joint projects.

A number of distinctions attest to our advisors’ excellent know-how:

Austrian TP Firm of the Year 2015

Our services:

Customized transfer pricing quick check

  • Efficient identification of transfer pricing risks and optimization potentials
  • Your advantages
    • All transfer pricing risks at a glance
    • Tailored solutions to reduce any existing risks, your tax burden, and your compliance costs in connection with transfer pricing

Overhaul of existing transfer pricing systems, or development of concepts and implementation of new systems – restructuring

  • Consideration of operational parameters (e.g. supply chain, controlling) and possible areas of improvement in terms of tax law (customs, VAT, withholding taxes, permanent establishment risk)
  • Creation of clear-cut function and risk structures as well as standardization of intercompany transactions
  • Impact analysis of function relocations abroad
  • Assessment of the customer base and business valuations
  • Drafting (or assistance with the drafting) of intragroup delivery, service, cost allocation, and license agreements, etc
  • Your advantages
    • Minimization of compliance costs
    • Reduced vulnerability of your transfer pricing system, yet increased controllability and predictability

Documentation of transfer prices

  • Joint development and implementation of efficient, customized documentation models in accordance with statutory requirements (centralized documentation concepts, master/local file or CbC report, etc)
  • If necessary, the reasonability of the transfer price can be substantiated with the help of the applicable databases (in particular, Bureau van Dijk’s AMADEUS database)
  • Advice on computer-assisted tools and web-based solutions for consistent cross-border documentation.
  • Your advantages
    • The transfer pricing documentation is tailored to your business and saves you time and money
    • You decide how much support you want from us: this could range from receiving documentation templates and individual consultations through to entrusting us with the entire documentation.

Defense of existing transfer pricing systems

  • Assistance during audits and mutual agreement procedures
  • Support during appeal procedures

Establishment of legal certainty

  • Drafting of unilateral ruling requests (pursuant to Sec 118 of the Austrian Fiscal Code), as well as initiation of APAs

Your Experts

Andreas Damböck

Auditor | Tax Advisor | Partner

Michael Kern

Tax Advisor | Partner

Clemens Nowotny

Tax Advisor | Partner

Norbert Schrottmeyer

Auditor | Tax Advisor | Certified and Court-Appointed Expert | Partner