(Re)count on ICON!

Transfer Pricing

The legal requirements and the burden of proof regulations require the creation of audit-proof documentation. 

"The contractor knows the facts. ICON knows the documentation regulations. Be on the safe side, (re) count on ICON!

The experts of our service line “Transfer Pricing” ensure that your transfer pricing is structured according to the arm’s length principle and document it in an audit-proof manner. Due to an increased focus on accurate transfer prices within company audits, it is essential that any advice and assistance is both competent and holistic. This not only minimises the risk of penalties but also provides considerable potential for strategic tax planning.

The legal requirements and the burden of proof regulations require the creation of audit-proof documentation. 

The experts of our service line “Transfer Pricing” ensure that your transfer pricing is structured according to the arm’s length principle and document it in an audit-proof manner. Due to an increased focus on accurate transfer prices within company audits, it is essential that any advice and assistance is both competent and holistic. This not only minimises the risk of penalties but also provides considerable potential for strategic tax planning.

The legal requirements and the burden of proof regulations require the creation of audit-proof documentation. 

The experts of our service line “Transfer Pricing” ensure that your transfer pricing is structured according to the arm’s length principle and document it in an audit-proof manner. Due to an increased focus on accurate transfer prices within company audits, it is essential that any advice and assistance is both competent and holistic. This not only minimises the risk of penalties but also provides considerable potential for strategic tax planning.

ICON Services

  • Advice on all transfer pricing matters
  • General risk analysis ("transfer pricing check")
  • Detailed functional and risk analysis of individual business areas
  • Benchmarking via database analysis 
  • Country specific transfer pricing documentation
  • Obtaining of advance rulings according to Section 118 Austrian Federal Fiscal Code [BAO]
  • Support with transfer pricing audits
  • Implementation of mutual agreement procedures and adjustments
  • Country by country (CbC) reporting (conversion)
  • Notification according to Austrian Act on Transfer Pricing Documentation [VPDG]

Head of Service Lince

Managing Partner, Tax Consultant, Head of Corporate Tax

Mitterlehner Andreas, MSc LL.B.

Specialisation

  • National Corporate and Group Taxation
  • Support with Tax Audits
  • International Tax Planning and Structuring
  • Tax Compliance
  • Reorganizations
  • Mergers & Acquisitions
  • business succession
  • Group restructuring
  • WiEReG
  • Funding Advice
  • research grant
  • process consulting
  • Tax Control Systems (IKS und SKS)
  • private foundations

Functions

  • Member for the Expert Committee for Tax Law of KSW
  • Board member of OÖ Austrian Experts​​​​​​​
  • ETAF’s main representative of the Platform for Tax Good Governance of the European Commission
  • Lecturer
  • Author
  • ​​​​​​​In-house workshops

Qualifications | Awards

  • "EY - Young Tax Professional of the Year" - Award 2013

News

NEWS  | 
PILLAR 2 | US MNEs exempt from Pillar 2 Taxes according to G7 Tax Deal
NEWS  | 
PILLAR 2 | selection of taxable constituent entity until 31.12.2024
NEWS  | 
PILLAR 2 | Austria avoids double taxation conflict with CFC-rules