Partner | Transfer Pricing & BMO
560 rue de Neudorf
Ralf is a Partner with Deloitte in Luxembourg with 15 years of experience covering the areas of transfer pricing, valuations and business model optimization. Ralf focuses predominantly on the financial services sector and worked for many of the key players in the traditional and alternative asset management (incl. private equity, hedge funds and real estate), insurance/reinsurance, and banking sector during his tenure in Tokyo, Hong Kong and Frankfurt.
Ralf`s financial services related experience covers a broad 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 include:
- Management fee splits incl. benchmarking, profit splits and cost plus remuneration approaches within the asset management space to remunerate investment advisory, investment research, distribution, principal function of regulated management companies (UCITS and AIFM ManCos) and support service activities;
- Funds transfer pricing and interaction between tax and regulatory (esp. Basel III), OECD based attribution of profits, assets and free capital to branches, sales credits, global trading models, service recharges, guarantees and trademark/technology royalties in the banking sector; and
- Investment management, reinsurance, service recharges, guarantees and remuneration for use of marketing/technology in the insurance sector.
Ralf 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 worked on more than 25 Advanced Pricing Agreements (APAs) and numerous high profile controversies on local and competent authority level covering tax authorities in the US, Japan, China, Singapore, India and across the EU.