Guest lecture by Benedikt Wenzel (Senior Manager) and Lisa Egger (Senior Associate) PwC

The presentation provided a comprehensive overview of the legal and business principles underlying transfer pricing. The arm's length principle, functional and risk analysis were emphasised as the basis for characterising a company, and common transfer pricing methods were discussed. Particular attention was paid to the practical implementation of transfer pricing systems and the derivation of arm's length margins using benchmarking.

Another area of focus was the classification of transfer prices at the interface between controlling and taxation. Practical examples were used to illustrate how conflicts of interest can arise between internal control and tax allocation of results, and the risks involved, particularly in the context of tax audits.

We would like to thank PwC for the very informative and practical guest lecture.