Within the framework of the increasing globalization of the markets, intragroup transactions – within corporate groups and SMEs working on the international stage – have increased rapidly. Within this context, the transfer prices for intragroup transactions have increasingly become the focus of fiscal company audits at home and abroad. Accordingly, complex regulations have been implemented in most countries in the meantime with respect to the definition and documentation of intragroup transfer prices. Furthermore, the national and international tax authorities have intensified their training of transfer price specialists over the last few years for the examination of intragroup transfer prices.
In order to avoid negative fiscal consequences, which can result from inappropriate transfer prices or the lack of or insufficient transfer price documentation (e.g. double taxation, financial penalties), proactive transfer price management is therefore recommended for the structuring and documentation of prices within the company. Since transfer prices also influence the tax ratio of the group, proactive transfer price management can also be used for the effective planning of the tax ratio of the group.