NERA was engaged to support client (US headquartered hidden champion in industrial products) and their counsel in appealing against transfer pricing tax assessment by German authorities.

For the appeals, we prepared an independent expert analysis that demonstrated that the German tax position is based on a missing or wrong understanding of facts. Proper fact consideration shows the German tax authorities’ assessment is not supported by tax law and is flawed, as no valuable intangibles have been transferred as part of a business restructuring: as usual, a distorted understanding of the facts leads to wrong tax conclusions, and the assessment of the German tax authorities is indefensible.