Study

Transfer Pricing Study 2023

The Management and Taxation of Transfer Prices for Distributors – Empirical Findings

Transfer prices are of particular concern to the finance departments of internationally operating cooperations. Therefore, Horváth working in collaboration with Flick Gocke Schaumburg produced the fourth Transfer Pricing Study to take a look at current challenges.

We surveyed more than 110 CFOs and executives from the areas of finance, controlling and tax from various industries in Germany and Austria. As in previous studies, in Section 1 we analyze the current relevance of transfer pricing, its importance for management control and its influence on corporate taxation. In doing so, we not only describe the current developments but also identify time period trends. In addition, this year we analyze the increasing digitalization in transfer pricing.

This year our main focus is the management and taxation of distributors. With regard to transfer pricing, we would like to highlight the following aspects:  

  • Which functional and risk profiles are common at distributors and do they change over time?
  • Which transfer pricing methods are used by distributors for the different transaction types?
  • What challenges does transfer pricing pose for the management of distributors and how are they dealt with?
  • What are the possibilities for automation in the design of integrated transfer pricing and controlling systems?

Answers to these and other questions, as well as many best-practice recommendations, can be found in the Transfer Pricing Study 2023.