Linz

LeitnerLeitner

tax audit advisory

A 4040 LINZ, Ottensheimer Straße 32
t +43 732 70 93-0 f +43 732 70 93-156
e linz.office@leitnerleitner.com

Linz

Salzburg

LeitnerLeitner

tax audit advisory

A 5020 SALZBURG, Hellbrunner Straße 7
t +43 662 847 093-0 f +43 662 847 093-825
e salzburg.office@leitnerleitner.com

Salzburg

Wien

LeitnerLeitner

tax audit advisory

A 1030 WIEN, Am Heumarkt 7
t +43 1 718 98 90-0 f +43 1 718 98 90-804
e wien.office@leitnerleitner.com

Wien

Perfectly matched to your requirements

Your personal advisor at LeitnerLeitner is dedicated to all matters on your agenda. Your advisor can draw on support from special teams of experts depending on the assignment, so that you always benefit from the expertise of our whole firm.

Transfer pricing

Tailored transfer pricing quick check

  • Identification of transfer pricing risks and optimization potentials
  • All potential transfer pricing risks at a glance
  • You benefit from tailored solutions to reduce any existing risks, as well as your tax burden and compliance costs in connection with transfer pricing 
     

Adaptation of existing transfer pricing systems / development of concepts for new transfer pricing systems and their implementation

  • Internationally coordinated, homogeneous systems reduce the risk of international double taxation as well as costly and time-consuming mutual agreement procedures, and contribute towards optimizing the group tax rate without forfeiting flexibility
  • In consideration of operational parameters (e.g. supply chain, controlling) and potential areas of improving the tax burden
  • Relocation of functions abroad
  • Adaptation of the operational, cross-border allocation of functions and risks in order to optimize your business processes and the cross-border allocation of your earnings
  • Creation of clear-cut functional and risk profiles, as well as standardization of intercompany transactions – reduction of compliance costs, and reduction of vulnerability of your transfer pricing system while increasing controllability and predictability

 

Documentation of transfer prices

  • Joint coordination and implementation of efficient documentation models (centralized documentation approaches, master/country file concepts, etc.) – reduction of administrative costs and easy to administer due to clear guidelines
  • Documentation of the reasonability of the applied transfer price (if necessary, also by means of database-assisted arm’s length data from Bureau van Dijk’s AMADEUS database)
  • Drafting / assistance with drafting of intragroup delivery, service, cost allocation, and license agreements, etc.

 

Participation in and assistance during audits and mutual agreement procedures, support during appeal procedures

  • defense of existing transfer pricing systems

 

Drafting of unilateral ruling requests (pursuant to Sec 118 of the Austrian Fiscal Code), as well as initiation of APAs

  •  security and predictability in cross-border intercompany transactions
Contact person
Dr.

Clemens Nowotny

Dr.
Tax Advisor | Partner

International tax law, group tax law and planning, transfer pricing, establishment of PEs and profit allocation,...
Dr.

Andreas Damböck

Dr.
Auditor | Tax Advisor | Partner

International tax law, corporate tax law, reorganizations, transactional services (M&A, private equity), transfer...
Dr.

Gebhard Furherr

Dr.
Auditor | Tax Advisor | Certified and Court-Appointed Expert | Partner

Austrian and international tax law, reorganizations, corporate tax law, transfer pricing...

Michael Kern

Tax Advisor | Partner

International and corporate tax law, M&A, transfer pricing, R&D...

Norbert Schrottmeyer

Auditor | Tax Advisor | Certified and Court-Appointed Expert | Partner

International tax law, corporate tax law, transactional services, transfer pricing, criminal tax law...

Natascha Stornig-Wisek

Tax Advisor | Partner

Austrian and international tax law, group tax law, non-profit organizations, public bodies, R&D, bookkeeping and...

Manfred Wänke

Auditor | Tax Advisor | Partner

Austrian and international tax law, reorganizations, succession planning, process/organizational consulting and...

Harald Galla

Auditor | Tax Advisor | Director

International tax law, group taxation, corporate taxation, value added tax, transfer pricing, M&A, real estate, private...