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Our Response to Escalating US Tariffs

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Rödl & Partner Tax Matters Volume 2025-5, published April 16, 2025​

Executive Summary

The Trump Administration has recently intensified its tariff policies, imposing significant tariffs on imports from various countries, with a particular focus on China and European countries. The new tariffs are part of a broader strategy by the Trump Administration to protect American industries and reduce trade deficits, but leading to increased costs for our Clients, U.S. businesses, and consumers.

Many German and other European-based inbound companies will be significantly impacted by at least the “Universal tariff” of 10 percent imposed by the Trump Administration. These tariffs increase the cost of goods imported into the U.S., affecting the profitability and competitiveness of businesses. 

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As of April 14, 2025*

By reevaluating transfer pricing policies in consultation with our Transfer Pricing team and outside customs experts, the declared value of your goods can strategically manage, potentially mitigating the financial impact of the tariffs during this period of uncertainty. 

How can Rödl & Partner Transfer Pricing Specialists Help?

Transfer pricing, which involves setting prices for transactions between related entities within a multinational corporation, plays a crucial role in managing the financial impact of tariffs. We have in place a robust and coordinated tariff assessment and decision tree approach to assist you on immediate and critical action steps to blunt or minimize the impacts of tariffs. Our transfer pricing team can assist to reevaluate transfer pricing policies and optimize the declared value of goods for customs purposes. This evaluation process should at all times be coordinated with a customs and tariff specialist to address the following issues:

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  1.  Customs Valuation (IMMEDIATE ACTION): Customs has many rules related to valuation. Transfer pricing is one of the ways to influence custom value via adjusting transfer prices of imported goods, potentially reducing the tariff burden. Some of the immediate strategies to address custom valuation include but not limited to: 

    I.   Strategic Pricing and Cost Management
    II. ​ Tariff Engineering 
    III.​ Negotiating with Suppliers 
    IV. ​Utilizing Customs Reconciliation Process

  2. ​ Compliance (IMMEDIATE ACTION): Ensuring that transfer pricing policies comply with both tax and customs regulations to avoid penalties and disputes. This could include but not limited to:​

    I.   Performing a Transfer Pricing Health Check 
    II.  Preparing a Robust Transfer Pricing Study
    III. ​Filing for a Customs Ruling (3 months to 3 years)​

  3.  Strategic Planning (LONG-TERM ACTION): Developing strategies that align with the company's overall financial and operational goals while considering the impact of tariffs. This could include but not limited to:

    I.​   Supply Chain Optimization and Diversification
    II.  Utilizing Free Trade Agreements (FTAs), Foreign Trade Zones (FTZs), and Bonded Warehouses
    III. Legal and Lobbying Efforts


Conclusion

In the current tariff environment, businesses must adopt a proactive approach to manage the financial implications of new trade policies. By leveraging transfer pricing strategies in consultation with customs experts, companies can better navigate the complexities of international trade and minimize the adverse effects of tariffs on their operations.


Please contact our Transfer Pricing Team for assistance:

Bea Petkova, CPA, EA, MST
Transfer Pricing Practice Leader
bea.petkova@roedlusa.com
+1 404 586 3549

Martin Tackie, PhD
Director, Transfer Pricing Services, Atlanta 
martin.tackie@roedlusa.com 
+1 404 525 3620

This publication contains general information and is not intended to be comprehensive or to provide legal, tax or other professional advice or services. This publication is not a substitute for such professional advice or services, and it should not be acted on or relied upon or used as a basis for any decision or action that may affect you or your business. Consult your advisors. The fact that you have received this publication does not create an accountant-client or advisory relationship between you and Rödl Langford de Kock LLP or any of its subsidiaries or affiliates. If you wish to hire Rödl Langford de Kock LLP or any of its subsidiaries or affiliates you will need to speak with one of our accountants and enter into a written agreement establishing the scope of engagement. We have made reasonable efforts to ensure the accuracy of the information contained in this publication, however this cannot be guaranteed. Neither Rödl Langford de Kock LLP nor any of its subsidiaries nor any affiliate thereof or other related entity shall have any liability to any person or entity which relies on the information contained in this publication, including, but not limited to, incidental or consequential damages arising from errors or omissions. Any such reliance is solely at user’s risk. Any tax and/or accounting information contained herein is based on our understanding of the facts and assumptions we have been asked to make for the purpose of this publication alone, and on the tax laws and/or accounting principles in effect as of the date of this advice. No assurance is given that the conclusions would be the same if the facts or assumptions change, or are not as we understand them, or that the tax laws and/or accounting principles will not change subsequent to the issuance of these conclusions. In addition, we do not undertake any continuing obligation to advise on future changes in the tax laws and/or accounting principles, or of the impact on the conclusions herein. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Rödl Langford de Kock LP.

Copyright © February 2025 Rödl Langford de Kock LP
All rights reserved. ​

Contact

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Bea Petkova

CPA

Transfer Pricing Practice Leader

+1 (404) 586-3549

Send inquiry

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Martin Tackie

PhD

Director Transfer Pricing

+1 404 525 3620

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