Approach & Competence
Working with the specialist
Regular and variable use of an in-house transfer pricing resource helps recognise risks in advance and to implement solution concepts. In other words, any TP related issues are taken into account right from the start as to business decisions and process adjustments. As a result, your company is in the position to save subsequent costs and to reduce tax audit risks or make these at least calculable.
A variable resource available in addition to your own staff, adapted to your requirements (e.g. 1-2 days per week), combines specialist know-how with cost efficiency.
Typical questions on the subject of transfer pricing
Efficient preparation/update of TP documentation
Do not reinvent the wheel: As a matter of course, existing information, documents and presentations of a group of companies should be used as basic guidelines for the preparation of TP documentation. It is, however, important to know which information is required to be part of the summary key document (Master File). Or: whether simply appending an adapted document suffices to fulfill parts of the required factual or adequacy documentation.
Whether a local or international approach is suitable and efficient to prepare, and regularly update, your TP-documentation depends on the structure and the TP-model of the entire group of companies. In any case: The international TP-documentation approach should be centrally coordinated by an internally responsible specialist, and corresponding TP-processes and TP-guidelines should be drafted and implemented accordingly.
TP enquiries from foreign group companies
What should the formal cost allocation invoice between related companies look like in order to be accepted by the German tax authorities? Which back-up documents should be available in the company records?
Does a so-called “profit mark-up” have to be added to a received / rendered inter-company service? If yes, how high does this have to be in order to fit consistently into the TP-system of the company?
Further Questions
Do I absolutely need a written contract signed in advance or are there other possibilities of minimising the risk of the non-recognition of an operating expenditure in a German tax audit?
In principle, retroactive adjustments of transfer prices are only permitted in Germany if agreed upon in advance between the parties and if they are based on previously defined calculation processes. De-facto, the translation of these regulations in the company‘s day-to-day business process leads to numerous questions, discussions and tax audit risks.
Uwe Kaestner
Master of Business Administration & Tansfer Pricing Expert
” I posses extensive and long-standing expertise as a transfer pricing (TP) specialist. I know both sides: in-house and outside consulting.”
Uwe Kaestner
Born in 1967
I worked as a consultant in Big Four accounting firms and as in-house consultant in a large multinational company from 1994 until July 2012:
- I have a long-standing professional experience as a tax expert and I am an internationally experienced senior manager with special expertise in transfer pricing.
- My profile is rounded off by my position in the tax department of a company as a TP specialist for Europe. This enables me to understand both sides, in-house and outside consulting, and therefore to find pragmatic approaches for the solution of problems.
Competent
Project responsibility as well as consulting in all significant fields in the area of TP, including:
- Documentation
(local as well as Master File approaches) - Design and optimisation of TP guidelines and TP processes
- Analysis, customisation and implementation of TP systems and TP methods
- Arrangement of value-chain processes and relocation of functions/business restructuring
- Support in the event of tax audits
Experienced
Excellent project management skills with leadership experience, assertiveness and negotiation skills. Significant projects in the past include:
Network partner
Uwe Kaestner / TP-EXPERTISE offers you a flexible and solution-driven service approach based on high competence and experience. The pragmatic approach is supported by trustful cooperation with a network of specialists and competent partners.
Uwe Kaestner / TP-EXPERTISE is an independent partner of an international network of transfer pricing specialists: Transfer Pricing Associates
TPA Transfer Pricing Associates
www.tpa-global.com
You are looking for a specialist for your network?
You are an auditing or tax consultancy firm with internationally acting clients, and your headquarters/branch office is located in the Rhine Main area?
You have noticed that your client has an increased need for transfer pricing knowledge and for a specialist who efficiently cooperates with you on the corporate client‘s side? A specialist, who implements transfer pricing projects and strategies promptly and supports ongoing processes?
You think it is of advantage, if potential transfer pricing problems on the client‘s side are identified at an early stage and subsequently discussed with you as their tax consultant? In this case, our collaboration could be of mutual advantage.
Success factors of the coorporation
A contact person with commitment and a strong sense of responsibility on the client‘s side for a special subject like transfer pricing enhances the communication and thus increases quality and efficiency of your expert advice.
A trustful cooperation between you as the external adviser, TP-EXPERTISE and the client facilitates the achievement of high synergy effects for all parties involved. Working hand in hand in a team is a crucial success factor.
Current Network Partners
FINEXA finanical expert accounting
www.finexa.de
HOLGER HAHN tax consultant
www.hahnstb.com