NERA, in cooperation with the European American Tax Institute, hosted a workshop in our Frankfurt office on 12 October 2009, on transfer pricing challenges and opportunities during the current economic downturn. Special attention was devoted to the topic of "relocation of functions" in light of the recent draft of new Administrative Guidelines, which specifies the relevant German transfer pricing legislation and regulations of this topic. Speakers, including NERA Affiliated Consultant Dr. Alexander Voegele and Principal Bastian Gottschling, used case studies as a basis for sharing transfer pricing theory and related practical experience. The topics addressed included: how to structure relocations of functions and to value relocated functions; how to determine margins for routine functions in the economic downturn; and how to value inter-company loans and to price interest rates and guarantee fees.