Dr. Yves Hervé Gives an Interview in Financier Worldwide’s “Annual Review: Transfer Pricing 2021 Germany”

25 June 2021
Yves Hervé

Transfer pricing is a major area of tax controversy in Germany. As of May 2021, the German Parliament approved the incorporation of the OECD Transfer Pricing Guidelines in Article 1 of the German Foreign Tax Code. This means functional contributions to intangibles—such as development, enhancement, maintenance, protection, and exploitation (DEMPE)—are set to become the core of future transfer pricing analysis and controversy. As a result, questions have arisen about new challenges companies will face as they try to achieve tax efficiencies while staying compliant with new German transfer pricing rules.

NERA Managing Director Dr. Yves Hervé recently gave an interview in Financier Worldwide’s “Annual Review: Transfer Pricing 2021.” In the interview, he addresses the challenges above and shares his expertise, considering the newly implemented guidelines, on subjects such as:

  • Recent significant developments in the transfer pricing arena;
  • The importance German tax authorities place on transfer pricing issues;
  • The challenges that arise when calculating appropriate transfer prices;
  • The challenges companies may face whilst trying to achieve tax efficiencies; and
  • How companies can prepare for tax audits in Germany.