Lars HemlingDie prozessuale Gestaltung von Verrechnungspreissystemen

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In 2015, the OECD published a comprehensive plan of measures in the form of the BEPS project to combat tax evasion. This action plan also provides more complex regulations for the determination and documentation of transfer prices. As a result, multinational companies have a considerable need to adapt their transfer pricing systems in order to reduce compliance risks. The BEPS project is forcing to determine transfer prices adequately to the value chain, which leads to challenges for multinational companies. This requires the implementation of corresponding processes and a more intensive cooperation between the tax department and operational functions is necessary.

In this study, the procedural design of transfer pricing systems of multinational companies in a post-BEPS world is analyzed with the help of expert interviews. The results of the study provide unique empirical insights into the cyclic phases from the determination of a taxation strategy to the defense of transfer pricing against tax auditors. Furthermore, this study examines the use of information technology to reduce compliance risks in cross-border inter-company transactions. In addition, new insights are offered how the tax department interacts with operational functions in the implementation of transfer pricing rules. Finally, the academic findings are anchored in a post-BEPS framework and the implications for practitioners are transferred into concrete recommendations for action.

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