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 2025

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

Wim Wuyts, who had been head of the specialist tax network since 2017, is moving on to a new role with WTS’s Belgian member firm
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations
Rafael Tena tells ITR about the ‘crazy’ Mexican market, ditching the hourly rate, and refusing to grow his fledgling firm in an ‘unstructured way’
It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure
Gift this article