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Experten für Experten

im internationalen Waren- und Dienstleistungsverkehr.

GRAF & KRINNINGER

Experts
for Experts

Specialists on Transfer Pricing

Our Focus:

Transfer Prices, the Centre of Attention of International Tax Authorities

Complex Challenge:

The Exchange of Goods and Services


Métier

Transfer Prices

Transfer pricing is becoming increasingly important in times of complex multi­national value chains. International allied companies cooperate ever more closely by means of an intensive exchange of resources. Business transactions are becoming increasingly internationalized.

Thus primary objectives of transfer pricing are the optimization of the group-wide tax rate, avoidance of double taxation and dispute avoidance and/or settlement.

Audits

In the course of tax audits, transfer prices and permanent establish­ments have lastingly moved to the top of the audit focuses. They are becoming increasingly important in in many countries around the globe. The control of prices for global transactions between affiliated companies and permanent establishment taxation are important instruments of the tax authorities to ensure the tax revenue. For taxpayers, the obligation to provide proof and the risk of unlawful double taxation is increasing accordingly; not least because of the so-called BEPS project (Base Erosion and Profit Shifting).

Against the background of inter­nationally intensified audit activities and the associated sanctions of fiscal and also increasingly criminal nature, the proper docu­mentation of the transfer prices is indispensable.

Anticipatory Actions:

In Implementation and Defence

Functional Interaction:

Internationally Well-Orchestrated



Knowledge

Facets | Strategy

In addition to tax aspects, there are primarily business and system-technical aspects which play an essential role in setting transfer prices. As entrepreneurs and practitioners, we also recognize your needs.

By means of our global network, we are able to assist you in all matters pertaining to the global development of your enterprise group.

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Computing Power:

Procedurally Streamlined



Technology

Overview | Control

The comprehensive ascertainment of the business and intragroup processes forms the basis for the evaluation and (re-) structuring of a transfer price system. It is the basis for the creation of an effective global value chain, tailored documentation and an efficient defense in case of audits or disputes.

A major challenge of transfer prices is the successful implemen­tation in the processes of the allied companies. By means of our comprehensive process consulting and the supporting training services, we help you to meet these challenges.

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Partners

Our Task

We support you in all transfer price-specific matters, in particular the design of transfer price systems, their implementation into your business processes, legally secure documentation and advice on defending your set-up in the course of an audit.

With our team consisting of tax advisers, specialist tax consultants, IT experts, controllers and process experts, we are able to fully support you within the scope of your transfer pricing matters.

We will also be happy to comprehensively help you with our expertise as advisers for advisers – with full client protection.

Dr. Mathias Graf

Tax Adviser, Specialist Consultant for International Tax Law

Markus Krinninger

Tax Adviser, Specialist Consultant for International Tax Law


The Team

Dr. Mathias Graf

  • Business School Graduate (German MBA), Tax Advisor, Doctorate in International Tax Law

Short Vita

  • April 2007 – Present Tax Adviser
  • Starting January 2004 Daimler AG, Stuttgart
    International Tax, Head of Transfer Pricing
  • Starting January 2003 PricewaterhouseCoopers AG, Munich
    Associate Corporate Tax

  • Activity Ephasis:
    • Optimization of tax planning in corporate groups
    • International tax consulting
    • Advice regarding tax audits
    • Mutual agreement procedures
    • Setting and documentation of transfer prices
  • Industry Focus:
    • Engineering and plant engineering, automotive, software, IT, construction service providers
  • Publications and Presentations:
    • Presentations at industry associations, chambers of industry and commerce (IHK), German association of tax consultants and auditors (LSWB) and various publications in professional journals

Markus Krinninger

Tax Adviser, Specialist Consultant for International Tax Law


Markus Krinninger

Master of Fiscal Affairs (Dipl. Finanzwirt (FH)), Tax Adviser, Specialist Consultant for International Tax Law

Short Vita

  • July 2011 – Present Tax Adviser
  • Starting July 2006 Brückner Group GmbH, Siegsdorf
    Commercial Manager (i.e. taxes, accounting, M&A)
  • Starting May 2002 PricewaterhouseCoopers AG, Munich
    Tax Adviser, Tax Manager
  • Starting December 1997 Bavarian Fiscal Authority
    (Bayerische Finanzverwaltung)
    Audits

  • Activity Ephasis:
    • Optimization of tax planning in corporate groups
    • International tax advice, taxation of permanent establishments
    • Advice regarding tax audits
    • Setting and documentation of transfer prices
  • Industry Focus:
    • Engineering and plant engineering, commerce, automotive, construction service providers

Convenient Location – Munich

Our Centre of the International Exchange of Goods and Services.