Baker McKenzie is the law firm with the best-known transfer pricing practice across Europe. The team is led by partner Stephan Schnorberger, who has been with the firm for 14 years. Four other professionals support Schnorberger in Germany. The firm deals with numerous disputes with the tax authorities, as well as advising on transfer pricing policy evaluation and adjustment for transactions as well as in relation to customs.
Alongside a leading German tax practice, Deloitte also offers a significant transfer pricing practice, including economic and business advisers as well as legal professionals. Jobst Wilmanns is the head of the transfer pricing department. Fellow partner Richard Schmidtke heads the Deloitte America / EMEA intellectual property group, an expert group on transfer pricing and IP. Martin Schmitt is another notable partner in the team, with specific expertise advising on transfer pricing for cross-border transactions involving Germany and the US.
The team was recently involved in the transfer pricing service model for a multinational running a digital business model. It evaluated the current cost-plus model the firm used and examined aspects of the system, such as profit allocation and withholding tax, in order to assess the validity of a cost-based remuneration in light of available alternatives.
The transfer pricing practice of Dentons works with the firm’s strong presence in cross-border transactions to provide assistance to firms on transfer pricing optimisation during and following a transaction. Michael Graf is one of the leading partners who works on transfer pricing policy optimisation.
The team has also advised a number of insurance companies, such as AIG, Pembroke and others, in their warranty and indemnity insurance and special tax insurance policies with all aspects of taxation, including the transfer pricing implications of their involvement. The firm also advised Enbridge on the transfer pricing implications of their $2.25 billion sale of a 49% participation share of a renewable energy portfolio to CPPIB.
EY holds one of the leading positions within the German transfer pricing market, with a multidisciplinary team including 190 professionals and 20 partners. Senior partner Oliver Wehnert is head of the transfer pricing team. Wehnert is also head of the TP practice in Switzerland and Austria, as well as leading the TP service area for Europe, India, Africa and the Middle East. Wehhnert focuses his practice on assisting with the transfer of intangible assets, as well as cross-border disputes and operating model transformation. The wider team covers all areas of transfer pricing with a wide variety of industry specialties.
Flick Gocke Schaumburg's transfer pricing department extends beyond advice on transfer pricing audits and disputes to include economic evaluation as well as TP policy design and implementation. The German law firm has a transfer pricing team including former auditors, accountants, lawyers and qualified accountants. The team includes 10 partners, such as notable practitioners Xaver Ditz and Hubertus Baumhoff.
The firm is currently assisting a watch manufacturer with the analysis of a proposed transfer of function to Hong Kong and the necessary adjustment to the company's transfer pricing policy for the transfer. The firm also continues to assist an automotive client with the implementation of a transfer pricing tax compliance management system.
LW Tax Lemaitre Wittkowski is a small tax boutique, which advises on transactions for small and mid-sized businesses, as well as assisting in transfer pricing disputes. The firm was founded by the two partners Claus Lemaitre and Ansas Wittkowski, who advise on the TP implications of a variety of cross-border transactions. The pair are also regularly involved in transfer pricing audits and disputes.
NERA Economic Consulting is a worldwide firm of legal and economic consultants and is regarded as one of the best independent firms in Germany. The team, through its combination of senior economists and legal advisors, is able to analyse data as well as suggest TP policies and assist in the implementation and defence of these policies. Yves Hervé, the managing director of NERA's global transfer pricing practice, is a key member of the German team. Chairman of the board Alexander Voegele is also a key practitioner in the transfer pricing team
The firm was recently successful in implementing a global three-way profit split for a leading manufacturing company. The profit split operates between the US, Germany and Russia and calculated the arm’s-length allocation key for the R&D activates of three entrepreneurs. The firm also assisted a digital company with identifying the contribution of various digital aspects to the multinational’s total profit. Through a value-contribution analysis and application of the game theory model, NERA defined and valued the contributions and the respective profit split between technology, user base and data owners.
German law firm Oppenhoff & Partner has a substantial offering in transfer pricing, offering advice on design, implementation and documentation of transfer pricing policy, along with defense of transfer pricing audits and assistance on obtaining APAs and MAPs. Partner Axel Bödefeld is the lead partner for transfer pricing matters.
The firm is currently assisting a leading car manufacturer in numerous APAs and MAPs procedures, including discussions with the Netherlands, Italy, the UK and the USA.
WTS is a global tax consultancy that actively refrains from conducting audits. The national practice has 25 transfer pricing employees across four locations in Germany, capable of covering all transfer pricing analysis, creation and implementation. It covers over 100 countries across the world, allowing it to offer transfer pricing advice to the largest multinationals. Maik Heggmair is the head of the transfer pricing team in Germany, as well as leading the global TP group of WTS Global. Torsten Hopp and Till Reinfeld are the other partners in the department. The firm also employs a substantial number of junior lawyers, economists and former revenue authority officials.
The team has assisted a leading Mdax listed automotive supplier with its restructuring across several European production sites, including DEMPE analysis and the implementation of a new TP system in order to comply with BEPS. The firm has also had success with their transfer pricing technology, which has so far been implemented by three DAX30 companies.