Transfer prices coming under ever closer scrutiny by the tax authorities

Transfer prices quantify payments for goods and services transferred within MNEs. To be accepted by the tax authorities around the globe, they must be determined in line with the principle of dealing at arm’s length. To explore about how multinationals apply the arm’s length principle in practice, surveys were conducted among German companies in 2015 and 2018. For instance, the new data shows the increase in tax disputes for the provision of services (up to 48%), licensing of intangibles (up to 41%), financing (up to 35%), and business restructuring (up to 32%), according to corporate TP and tax managers.