Comprehensive project experience in transfer pricing planning projects and global compliance projects
Expert in advance pricing agreement projects
Frankfurt
@alvarezmarsal
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Cheng Qiu is a Director with Alvarez & Marsal Tax in Frankfurt. She specializes in transfer pricing. With more than 10 years of transfer pricing experience, Ms. Qiu has collaborated with clients in various industries, with recent projects on electric vehicles, digital business, logistics, life science, chemical, automotive, electronics and consumer goods.
Ms. Qiu has comprehensive project experience in transfer pricing planning projects using profit split models, particularly in the context of business restructurings within the pharmaceutical and consumer product industries during post-merger integrations. She has worked on multiple advance pricing agreement (APA) projects involving Germany, Korea, Japan, Belgium, and the U.S., for distribution and co-entrepreneur business models in the automotive industry; and has restructured intragroup service charges for automotive suppliers in Germany.
Ms. Qiu also played a crucial role in supporting large Chinese-headquartered groups in their expansion into Europe, focusing on transfer pricing and international tax strategies and collaborating closely with top management to design global value chains and business models from a tax perspective. She also managed a court proceeding for a transfer pricing dispute in Germany.
Prior to joining A&M, Ms. Qiu operated a consulting boutique providing transfer pricing services to German-headquartered multinational groups. Previously, she worked with Ernst & Young for four years (including two years in Shanghai), Deloitte and KPMG in Germany, focusing on transfer pricing.
Ms. Qiu earned a bachelor’s degree in accounting from Hangzhou Dianzi University in China and a master’s degree in accounting, auditing, and taxation from University of Siegen. A Chartered Tax Advisor in Germany, Ms. Qiu is fluent in Chinese, English, German.
Ein BFH-Urteil bringt frischen Wind ins Transfer Pricing: Lokales Marketing kann eine verdeckte Gewinnausschüttung auslösen – auch ohne direkten Konzernbezug. Das Urteil ist ein Weckruf für internationale Steuerabteilungen.
The BFH is bringing a breath of fresh air into transfer pricing: Local marketing efforts may trigger a hidden profit distribution (verdeckte Gewinnausschüttung or vGA) — even without a direct group connection. The court decision is a wake-up call for international tax departments.
As of 1 January 2025, Transfer Pricing compliance in Germany is subject to significantly enhanced procedural requirements. In particular, Transfer Pricing Documentation, including the Transaction Matrix, the Master File, and documentation of extraordinary transactions, must be submitted within 30 days following the announcement of a tax audit.
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On 14 June 2024, the Inland Revenue Authority of Singapore (IRAS) released the 7th Edition Singapore Transfer Pricing Guidelines, which has introduced changes to the treatment of domestic loans.