Prof. Dr. Stephan Rasch is a transfer pricing partner in PwC's Munich office. He has twenty-one years of experience in international taxation and transfer pricing. Before joining PwC in December 2013, Stephan worked with another Big Four firm as transfer pricing partner. Stephan advises clients in tax matters associated with cross-border transactions, including permanent establishment issues and value chain transformations. He has worked on a broad variety of transfer pricing projects for various industries, including the automotive and automotive supplier industry as well as chemical and pharmaceutical industries, the machinery tool, and IT sectors. Stephan's clients include German-based DAX companies as well as European and US multinationals. He serves as Global Relationship and Lead Partner for various companies.
Stephan has led numerous global documentation projects, inter alia for German-based multinational entities implementing and maintaining a modular global core documentation concept. He has also gained significant experience in VCT projects during the last two decades years. He is successfully involved in German and European tax/transfer pricing audits defending the restructuring and/or the transfer of intangible property in business model reorganizations, including particularly cases involving Switzerland as a principal location. Stephan's experience with Mutual Agreement Procedures include bilateral and multilateral cases as well as the negotiation of bi- and multilateral Advance Pricing Agreements. Finally, he is involved in tax court litigation relating to transfer pricing cases. He has been appointed as German national reporter on Subject 1 "Dispute Resolution" for the 70th International Fiscal Association (IFA) Congress in Madrid in 2016.
Stephan has published a volume on transfer pricing legislation in international German, bilateral and European tax law. He is co-editor and co-author of one of the leading transfer pricing publications in Germany, Handbuch Internationale Verrechnungspreise, Bitte vor das as well as co-editor co-author of Gosch/Kroppen/ Grotherr, DBA-Kommentar, a leading commentary on double tax treaties. He is editor of the Internationale Steuer-Rundschau (ISR), a German international tax journal and contributes articles to national and international tax journals on a regular basis. Stephan is professor of international tax law at the University of Augsburg and is a frequent speaker on transfer pricing at national and international seminars.
Stephan is a member of the Munich Bar, the International Fiscal Association (IFA) and the IFA Bavaria board. Stephan holds a PhD in International Tax Law and a degree in law from the University of Bochum. He is a tax lawyer (Rechtsanwalt/Fachanwalt für Steuerrecht).