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

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.
The German Federal Ministry of Finance (BMF) published the final version of the revised administrative guidelines on 12 December 2014 for the amended German transfer pricing (TP) rules (Section 1(3)(d) and (3)(e) of the German Foreign Tax Act (AStG)) governing cross-border intra-group financing transactions. The most important changes are summarized in this article.
In this article, we analyze key figures from the OECD report for insights on where Germany stands in relation to the rest of the world and its own historical performance on dealing with MAP and APA cases. We also offer key recommendations for businesses to pursue transfer pricing certainty.
Understand the impact of the new Growth Opportunities Act (Wachstumschancengesetz) on Germany’s transfer pricing rules for intercompany financing.
Latest insights The latest insights from Cheng Qiu's team
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.