Partner | Transfer Pricing & Value Chain Alignment
20 Boulevard de Kockelscheuer
Ralf is Partner with Deloitte in Luxembourg with an extensive international track record and over 17 years’ experience advising clients on transfer pricing, international tax and business model optimization. Ralf focuses predominantly on the financial services sector and worked for many of the key players in the asset management (traditional and alternative), banking and insurance sectors during his tenure in Tokyo, Hong Kong, Frankfurt and Luxembourg. His experience covers a broad range of complex and global engagements on transfer pricing planning, restructurings, operationalization, documentation and tax controversy. He worked on more than 30 Advanced Pricing Agreements (APAs) and numerous high profile controversies on local and competent authority level with tax authorities in the US, Japan, China, Singapore and across the EU.
Ralf`s financial services related experience covers a wide range of topics along the transfer pricing life cycle ranging from planning and policy development, implementation/operationalization, restructurings, documentation, tax provision/risk reviews and audit defense/controversy related work. Specific examples across the asset management, banking and insurance sectors include:
- Transfer pricing issues of cross-border distribution, investment management, administration and fund production in the asset management sector using fee splits (incl. benchmarking approaches using Lipper/Mercer and profit splits);
- Consideration for the unique role of regulated management companies under the UCITS/AIFMD regime and benchmarking approaches using third party ManCo data;
- Tax impact of regulatory developments (esp. Basel III) and increased liquidity/capital requirements on determination of free capital for banking branches and funds transfer pricing (FTP) for pricing the provision of liquidity;
- Attribution of financial assets, profits and branch capital to permanent establishments in banking sector based on the Authorized OECD Approach (AOA);
- Tax treatment and BEPS impact on core banking transactions covering global trading, capital markets and underwriting, investment banking, loan origination and syndication, securities lending, custody banking and sales credits;
- Transfer pricing approaches for reinsurance and captive insurance arrangements including substance considerations and benchmarkings;
- Attribution of assets, profits and branch capital to permanent establishments in the insurance sector based on the Authorized OECD Approach (AOA);
- Intercompany services and management activities in the financial service; and
- Tax treatment of intangibles covering trademarks and technology and guarantees
Ralf also supported clients across a broad range of other key industries such as technology, manufacturing and consumer goods on designing, implementing, documenting and defending their transfer pricing policies and practices ranging from profit attribution to permanent establishments, procurement, R&D and centralized intellectual property (“IP”) structures to manufacturing, sales/distribution, shared services and treasury (loans, cash pooling, netting, POBO/ROBO, guarantees and captive insurance) arrangements. In the light of the OECD/G20 BEPS initiative, focused on both the operational as well as tax effectiveness of value chains in light of the ongoing transformation of business models and regulatory changes.
Ralf holds a MBA / Degree in Economics from SDA Bocconi School of Management in Milan, Italy and has also studied at the Wharton Business School in Philadelphia, USA and International University of Japan.