Several life sciences companies faced transfer pricing audits of their German subsidiaries, with tax authorities challenging percentage-of-revenue distribution margins, as well as other intercompany services and tangible-goods transactions between local affiliates.
CRA Transfer Pricing expert, Gene Tien, led a team to successfully defend these assertions and limited the contagion effect of adjustments across multiple jurisdictions.
Prior to the audits, the team prepared global transfer pricing documentation for the companies designed from a risk-management perspective, allowing them to defend the underlying transfer pricing policies and analyses. Since audits spanned multiple regions within Germany, the team, which included law firm and accounting firm backgrounds, worked with separate legal and accounting advisors to resolve distinct historical issues, including prior-year restructurings.
