New German Guidelines: Challenges to Expect in Tax Audits and Practical Mitigation Strategies

05 October 2021
Hosted By: NERA Economic Consulting

Since the end of 2020, the German tax legislation and transfer pricing guidelines have been modified and will have far-reaching consequences for multinational taxpayers. The new regulatory environment will encourage German tax authorities to claim higher and more frequent income adjustments in tax audit controversies. Based on experience from current tax disputes, the challenges that multinational taxpayers should expect can largely be anticipated, along with how they can mitigate risks from future tax controversies.

On Tuesday, 5 October, at 16.00 CEST, NERA Economic Consulting’s Managing Director Dr Yves Hervé and Director Philip de Homont will hold a webinar in German on “New German Guidelines: Challenges to Expect in Tax Audits and Practical Mitigation Strategies.” Based on practical case studies, our speakers will discuss:

  • How the integration of the OECD’s DEMPE approach on intangibles in the German regulatory framework should be addressed in German TP documentation.
  • How and when traditional benchmarking analysis will be challenged and how to mitigate against risk of tax assessment by tax authorities applying alternative methods of testing?
  • The implications for intangible valuation in the context of business restructuring.

On Tuesday, 28 September, at 14.00 CEST, the same webinar will be held in German. To register for the German webinar, click here.

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Dr. Yves Herve
Managing Director,
NERA Economic Consulting


Philip de Homont
NERA Economic Consulting


Dr Yves Hervé is a Managing Director in NERA's Global Transfer Pricing Practice and operates from NERA’s Frankfurt office. Dr Hervé has been a fully dedicated TP professional since 1999. Prior to joining NERA, he was a Transfer Pricing Partner at one of the Big Four accounting firms, then the German Tax Leader of the global Value Chain & Digital Transformation practice at another Big Four firm. In the course of his professional career, Dr Hervé has covered all major TP consulting issues for global clients, from integrated value chain structuring and TP planning to global TP compliance issues and documentation, TP economic solution design, IP valuation, cost contribution solutions, business restructurings, tax audit defence, and dispute resolution. His client portfolio covers global multinationals across a broad segment of industries (in particular life sciences, chemical and industrial products, transportation and logistics, automotive, energy, consumer, high-tech).

Philip de Homont is a Director in NERA’s Transfer Pricing and Intellectual Property practice. He specialises in TP litigation support for international corporations and law firms. His passion is to prepare clear and concise reports for complex cases based on rigorous analysis. He has worked for clients in a variety of industries, particularly in the high-tech machine industry, the digital economy, and the consumer goods industry. He has worked successfully with various international law firms, tax advisors, and multinational firms on cases in the US, throughout Europe, and several other countries. 

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