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The field of transfer pricing is perceived as extraordinarily complex and resembles a jungle of regulations worldwide in which only specialists know their way around, although in principle everything could be reduced to a globally unified standard: the arm’s length principle. According to this principle, cross-border business relationships between related parties or transactions between associated enterprises should be established as if they were conducted with a third party for tax purposes and thus for the allocation of taxation rights to different countries. Consequently, a market-conform action should be introduced into a multinational enterprise group, the economic unit of the group of companies should be partially ignored and the individual associated business units should be taxed on the basis of the separate entity approach. In order to ensure this, countries around the world have issued regulations. International standard setters such as the OECD or UN have drawn up extensive guidelines.

It was difficult for us to enter this world and we would have liked to have had a manageable and practical book to help us get started. In view of this background we want to offer an entertaining, practical and structured introduction to the transfer pricing world with this book, which provides a necessary orientation and guidance for both beginners and for those who have been working in this field for years.

This book is therefore addressed to all those who are (or want to be) interested in the topic, especially newcomers to the field of transfer pricing, students, especially in the field of law and economics, who are interested in the area of tax law or transfer pricing, students of law and economics, who are dedicated to tax law or tax theory, trainee tax consultants, consultants in the field of corporate taxation and transfer pricing, employees of tax authorities, employees in corporate tax departments and in controlling, public prosecutors and judges.

We have deliberately chosen to base our approach on a concept that focuses on practical case application. The case study developed for this purpose is intended to introduce the topic. It focuses on a fictitious multinational enterprise group and its cross-border transactions. In each chapter, specific aspects are addressed in a structured manner, all of which relate to the one initial case. The focus in this book is clearly on a practice-oriented approach and basically covers all common transfer pricing issues. As the „world” of transfer pricing seems endless, we like to point out, that there are many aspects of this topic and individual special issues which are subject to specialist literature. Also, please bear in mind that all circumstances and effects depend on the individual case given. However, after studying the book or individual chapters, you will be able to manoeuvre your way through the jungle of regulations, to basically classify and solve transfer pricing issues, to address the right questions and you will have developed risk awareness.

In a nutshell: the book serves as a helpful tool for practical work.

This English language version of the original publication concentrates on the application of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and refers to the United Nations Practical Manual on Transfer Pricing for Developing Countries. The worldwide transfer pricing standards are defined here, allowing us to write a book that is generally applicable to all jurisdictions. At the same time, reference is repeatedly made to the design of the arm’s length principle in German tax law as a practical example.

Berlin, May 2021, Eva and Dr. Stefan Greil