Cheng Qiu

Director
10+ years of transfer pricing experience
Comprehensive project experience in transfer pricing planning projects and global compliance projects
Expert in advance pricing agreement projects
Frankfurt
@alvarezmarsal
LinkedIn
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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. 

Insights By This Professional

On February 13, 2026, the German Federal Ministry of Finance (Bundesfinanzministerium or BMF) released a draft of new administrative principles on the definition and creation of permanent establishments (PEs) under domestic tax law (§ 12 AO, § 13 AO) and double tax treaties (Art. 5 OECD Model). The draft represents the most significant update to Germany’s PE framework since the last amendment in 2026 and incorporates extensive BFH case law as well as the OECD’s 2025 Model Convention and Commentary.
Germany streamlines cross-border tax dispute resolution with new electronic procedures and clarified arbitration rules — marking a major step toward greater efficiency and international tax alignment.
Germany proposes stricter rules on capital allocation for insurance permanent establishments – a shift that could significantly impact transfer pricing models.
Germany’s top court redefines transfer pricing rules—substance now trumps paperwork in intercompany start-up loss deductions.
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Thought Leadership
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.