Merck Group’s Frank Schoeneborn discusses patent box controversy, negative press and issues of confidentiality

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Merck Group’s Frank Schoeneborn discusses patent box controversy, negative press and issues of confidentiality

Frank Schoeneborn, head of operational transfer pricing at Merck Group, discusses the power of public opinion and the impact it is having on transfer pricing in an interview with TPWeek.

Schoeneborn has expressed his views on some of the most topical transfer pricing issues, including the arm’s-length versus profit split debate, BEPS progress, issues over confidentiality and the increasingly negative press coverage that transfer pricing is receiving.

“These days, press drives the public opinion more than ever. Even small matters might turn into big scandals very soon,” said Schoeneborn.

The interview provides an insight into the brewing controversy behind patent boxes and the growing emphasis being placed on people functions.

“Listening to the phrase patent boxes creates no sympathy. What should an individual think? These structures were invented for saving taxes,” said Schoeneborn.

Schoeneborn also shares his views on what transfer pricing methodology could look like in a decade, providing predictions on the future of the profit split.

The full interview is available on TPWeek.

Register for a free trial on TPWeek to read Frank Schoeneborn’s comments in full.

more across site & shared bottom lb ros

More from across our site

Fragmented pillar two taxation and increased use of AI by tax authorities have left clients fearful of heightened disputes exposure
Grant Thornton Advisors’ latest acquisition has produced the fifth-largest US advisory firm by revenue, but there’s still a clear gulf between it and the big four
Crowe joins Grant Thornton, WTS and Ryan in attracting PE investment, suggesting that dealmakers remain bullish on the tax advisory sector
HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards
The purchase of Marosa represents the second major tax tech consolidation this week, raising questions of a broader industry trend
Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments
Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed
The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another
Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings
Gift this article