Transfer Pricing Survival Guide

Transfer Pricing is an issue that has material implications for tax risks faced by MNEs. Yet, pragmatic guidance on identifying and managing transfer pricing risk is lacking. Consequently, CFOs and other stakeholders tend to underestimate risks while overestimating the costs for mitigating such risks. The first objective of the Survival Guide is to shed light on typical transfer pricing risks and provide an intuitive "risk matrix" that is designed to help CFOs as well as tax advisors to develop a quantitative understanding of the relevant risks. The second objective is to outline targeted mitigation strategies. The mitigation strategies outlined in the Survival Guide are based on pragmatic considerations rather than complex analysis. The aim is to provide you with concise explanations and help you to differentiate between tasks that are considered a "must" for mitigation purposes and those that can be regarded as merely "nice to have" The immediate utilization of the Survival Guide is as a frame of reference for making informed decisions about the scope and target of your transfer pricing projects. The Survival Guide presents a framework for thinking about transfer pricing risk that will also benefit tax professionals as well as academics with an interest in understanding the nature of transfer pricing risks.

Oliver Treidler is CEO and founder of TP&C GmbH based in Berlin. TP&C is an independent provider of consulting services for projects focused on transfer pricing. The consulting philosphy of TP&C. which is also the Leitmotiv of the "Survival Guide" and"Transfer Pricing in One Lesson", is rooted in a business perspective on transfer pricing. Oliver frequently publishes on transfer pricing issues and actively contributed to various public consultation procedures of the OECD BEPS project. He holds a master's degree in international economics and European studies from the Corvinus University of Budapest (M.Sc.) and a Ph.D in economics from the University of Würzburg.