Dr. Yves Hervé and Dr. Jens Rubart of NERA Economic Consulting explain how the German Foreign Tax Act, introduced in January 2022, affects retroactive price adjustments and the definition of intangibles.
Yves Hervé and Jens Rubart of NERA Economic Consulting explain why a Federal Fiscal Court decision regarding intercompany financing will have significant implications for taxpayers in Germany.
Yves Hervé and Philip de Homont of NERA Economic Consulting discuss transfer pricing solutions in situations where multiple entities make unique and valuable contributions to a business.
Yves Hervé, Philip de Homont and Salem Saljanin of NERA Economic Consulting discuss the transfer pricing challenges that multinational automotive suppliers increasingly face and present innovative solutions in a post-BEPS setting.
Yves Hervé and Tom Braukmann of NERA Economic Consulting discuss the changes to Germany’s transfer pricing regulatory environment, with a specific focus on future tax audits.
Yves Hervé and Philip de Homont of NERA Economic Consulting discuss plans for an alternate proactive strategy to defuse TNMM benchmarking-related tax controversies on audits in Germany.
Yves Hervé and Philip de Homont of NERA Economic Consulting discuss the potential impact of the key changes proposed in the German Ministry of Finance’s transfer pricing administrative guidelines.
Yves Hervé and Philip de Homont of NERA Economic Consulting present a case study on considering the data-based economic valuation of user contributions.
Niraja Srinivasan, Yves Hervé and Philip de Homont of NERA Economic Consulting take a closer look at the transfer pricing challenges and solutions that have emerged from restructuring expenses during the coronavirus pandemic.
Yves Hervé and Philip de Homont of NERA Economic Consulting explain how multinationals can plan to mitigate losses faced in their manufacturing transfer pricing model.
Yves Hervé and Philip de Homont of NERA Economic Consulting assess how companies can suitably address concerns surrounding transfer pricing (TP) license agreements.
ITR European Tax Awards winners Yves Hervé and Philip de Homont of NERA Economic Consulting talk about the evolving European TP landscape and the COVID-19 impact on client work in a podcast.
Yves Hervé and Philip de Homont of NERA Economic Consulting present a real-life case study explaining how the correct transfer pricing techniques can somewhat alleviate the harsh economic effects of the pandemic.
Yves Hervé and Philip de Homont of NERA Economic Consulting analyse how the economic decline caused by the coronavirus outbreak may prompt multinationals to alter their transfer pricing models.
Managing Director Yves Hervé and Associate Director Philip de Homont of NERA Economic Consulting explain how, and under which circumstances, cost-plus solutions for contract R&D arrangements can be sustained in a post-BEPS age.
Yves Hervé and Philip de Homont of NERA Economic Consulting show how taxpayers can adapt their defence strategies to the DEMPE concept, focusing particularly on the use of third-party agreements.
It is likely that many tax disputes will arise from the new definition of hard to value intangibles (HTVI) in the OECD's transfer pricing (TP) guidelines.
In our last article, we described the challenges that the digital transformation poses for transfer pricing (TP). In this article, we want to show how emerging business interdependencies can be translated into new TP models.
This article describes the challenges that the digital transformation of the economy poses for transfer pricing. In the next article of the series, it will show how these interdependencies can be translated into new transfer pricing models.