Transfer pricing

A global view on a business-critical, fast-evolving issue.

Organisations that span international borders are facing increasingly complex regulatory and tax issues in the different jurisdictions where they operate. Transfer pricing is at the top of the tax priority list for many privately owned and large businesses. We offer a range of solutions for transfer pricing management so you can ensure compliance with Government regulations.

Our approach

Through our global partnership, we are able to provide vital information and support to our clients, tracking developments on legislation and court/tribunal rulings, through our transfer pricing experts who have in-depth industry knowledge both locally and internationally.

We utilise the expertise of teams across multi-disciplines, including economists, to help with value chain analysis: a vital tool to align transfer pricing with economic value creation and establish transfer prices for intangibles. Data is the foundation for a robust transfer pricing regime. Recognising this, we have created databases and tools such as a cloud-based system to ease reporting under the EU's DAC6 directive.

Our service begins with a diagnostic risk assessment that seeks to highlight areas for savings, as well as exposure. We then work closely with you to make sure you can meet your documentation obligations and optimise your tax positions.

Our services

• Strategic advice on all aspects of transfer pricing
• Master file, local file and country by country reporting
• Tax audits, mutual agreement procedures
• Value chain analysis and transformation
• Economic analyses, including commercial benchmarks, loan benchmarks, and license benchmarks
• Cash pools and other integrated group-wide financing systems
• Transfer of functions, valuation of transfer packages, exit taxation
• Valuation of hard to value intangibles

Our tools and solutions

With Transfer Pricing Genie, we offer a digital transfer pricing documentation solution that is a more efficient approach to increase transfer pricing processes.

We also offer database access, including Bloomberg and RoyaltyStat, as well as the automatic transmission of country by country reports (CBCR) and data exchange through our Huddle platforms.

Get in touch

If you require support with regulatory and tax issues in different jurisdictions, please get in touch today using the form below.

Webinar series - Transfer pricing controversy

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Latest reforms: TP, PEs & DPT

In light of growing efforts to align UK tax rules with global best practices, HMRC is taking steps to reform current UK legislation, particularly with respect to transfer pricing (“TP”), permanent establishments (“PEs”) and diverted profits tax (“DPT”).

New UK Transfer Pricing Rules 2023

What are the new requirements? In December 2022 the UK government published the draft secondary legislation for comment (The Transfer Pricing Records Regulations 2023) which requires the largest multinational businesses operating in the UK to maintain a Master File and a Local File in the prescribed and standardised format as set out in the Organisation for Economic Co-operation and Development...