Study

The topic of transfer prices is of central importance for the finance departments of international corporations. Together with Flick Gocke Schaumburg, we are therefore analyzing the current challenges in the transfer pricing environment for the fifth time. For this comprehensive study, we surveyed over 110 CFOs and managers from the finance, controlling and tax departments of various industries in Germany, Austria and Switzerland. 

In the first part of the study, we shed light on the current relevance of transfer pricing for companies – both in its role as a business management tool and its influence on the taxation of companies and the practical implementation of operational transfer pricing. In doing so, we not only highlight current developments, but also identify long-term trends. 

The second part of the study is dedicated to the central question of the extent to which management and tax requirements are already integrated into transfer pricing. We analyze the following aspects, among others: 

• To what extent are tax transfer prices used for management purposes?  

• Were the requirements of the tax department taken into account in conceptualizing the management model?  

• To what extent have problems arisen due to a divergence between the tax transfer pricing concept and the management model in company audits? 

Answers to these and other interesting questions as well as practical best practice recommendations can be found in the Transfer Pricing Study 2025.