From time to time, we like to sit back, take a breath and think about what happend in the course of the last months. It is also an opportunity to thank our business partners (and team members) and recap some events and workshops. Yes, sometime we also dare to look ahead a little. Since starting TP&C, I have managed to write about the main developments on a (almost) bi-annual basis. The earlier blog posts (in German) are available on our German homepage. Going forward I vow to also blog in English from time to time (also I think it is time our team contributes on these posts as well). A translation of the last blog from Summer 2022 will kickoff the english blog... Happy reading
And Q4 2021 is already over…
2021 was a pleasing year for TP&C overall. First and foremost, we continued our trusting cooperation with our regular customers and partners. In many cases, we were able to intensify or expand existing cooperations. The long-term relationships with our partners in particular make us proud and happy. We were also able to win some exciting new mandates. Recommendations from our regular customers contributed significantly to this (many thanks for this!).
However, 2021 was also challenging, especially in the form of conflicting tax audits. Often, but unfortunately not always, the outcome was conciliatory. At times, the disputes with the tax auditors involved were unpleasant and left a bitter aftertaste. Particularly in the case of transfer pricing, a healthy dispute can sometimes be fun (salt in the soup) and is also the conceptual basis of the arm’s length principle. Often, the discourse actually leads to a result that is acceptable to both sides. Even in tough negotiations, there was rarely cause for a bitter aftertaste. Unfortunately, there was sometimes a lack of eye-to-eye discourse this year. Lamentable in some cases was a de facto reversal of the burden of proof as well as arbitrary audit findings.
Perhaps it was simply one of those years, or perhaps the new administrative principles on transfer pricing caused this development? Shadowy sides of our dream job, but we will simply have to dress warmer and at least had the opportunity for some (critical) publications. During my guest appearance on the Fiona Show (December), I was also allowed to vent a bit in this regard (the publication is still pending). On this occasion I also tried (again) to “advertise” for a reasonable, pragmatic, handling of the arm’s length principle. It is questionable whether these attempts can achieve anything. Now that the so-called Pillar 1 of the OECD reform has become reality, we are likely to see increasing skepticism towards the arm’s length principle. Too bad.
Unfortunately, we did not find a permanent addition to our small team in Q4. But we are still looking. In any case, Tom, Lisa and Nastja have been fully involved in 2021 and have made great progress. The fact that the three of them are still reasonably enthusiastic with transfer prices makes me look optimistically ahead for 2022.
In Q1 we will be holding numerous workshops together, at least four, and there are already exciting projects on the table again. Enough opportunity for the entire TP&C team to develop further. Other topics on our agenda include “Taxcasts” (online transfer pricing seminars) and “InnerSource” (application of CCAs of decentralized software development). Admittedly, these topics have already been on our ToDo list since Q2 2021. In the spirit of good New Year’s resolutions, we will work harder to finally bring these projects to life (products or publications) and present them to a wider audience. Of course, I would also have to finish my publication on the basic topic of an arm’s length definition of “value added” in post-BEPS (Pillar 1) times. Even on my third attempt, I still can’t leapfrog writer’s block on this publication… So, room for improvement is of course abundant.
For 2022, I wish our partners much success and, above all, good health!
Oh yes, there is also the Christmas party upcoming… Maybe a good occasion for the next blog post.
Oh yes 2.0, we also want to put a small team brochure on the homepage soon. So it remains exciting :-)
OliverTreidler - 16:24:07 | Add a comment
From time to time we are invited to participate in online seminars and conferences - often in collaboration with our business partners. In case the hosts publish the content on YouTube, you can find a a respective link below;
Currently, videos are available on the following issues:
Transfer Pricing in Germany - General Overview (May 2023 - with Quantera Global)
Transfer Pricing for InnerSource (November 2022 - with Kolabri.io)
Transfer Pricing Developments Poland, Germany, Austria and The Netherlands (July 2021 - with Quantera Global)
Transfer Pricing Developments in Germany (June 2020 - with Quantera Global)