Uwe Zoellner

uːvə tsœlnɐ
Transfer Pricing Economist
London
About

With nearly a decade of international transfer pricing experience, Uwe draws on deep expertise gained from working in both the UK and Germany. He supports multinational businesses across a range of sectors—including Automotive, Technology, Financial Services, and Real Estate—in navigating complex transfer pricing planning and controversy matters.

Uwe offers clients practical solutions tailored to their needs. His work spans transfer pricing risk assessments, policy planning, valuation of intangible assets, intra-group financing, and the defence of cross-border arrangements during tax audits. He also assists with dispute resolution processes, including support with Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs).

Areas of FocusTax

EXPERIENCE

  • Designed transfer pricing group policies, including conducting DEMPE analyses and detailed profit split analyses.
  • Valued intangible assets as part of a company acquisition, with the aim of integrating them into a cost-sharing arrangement.
  • Prepared Advance Pricing Agreement (APA) applications and participated in discussions with Competent Authorities.
  • Analysed investment portfolio management and advisory services in the context of private equity funding arrangements.
  • Conducted debt capacity and interest rate analyses related to intra-group financing for real estate acquisitions, group restructuring projects, and both physical and notional cash pool arrangements.
  • Provided transfer pricing planning support to a cybersecurity provider during the phased transition of its senior management team from the UK to the US.
Languages
  • German
  • English
Education

    Publications

    "Lifecycle of a transaction: transfer pricing considerations" Tax Journal, May 2025.

    Connect

    Phone

    +44 (0) 20 7796 6534
    (Work, London)
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