Transfer Pricing Services

We work with international organisations to provide a range of transfer pricing services.

Compliance

As multinationals globalise and countries adopt stricter rules for transfer pricing, the compliance requirements associated with transfer pricing reporting and documentation have increased.

Our transfer pricing compliance and planning advice includes risk reviews to identify and analyse priorities and develop policies. We work regularly with companies, small and large, that do not have dedicated in-house expertise in transfer pricing to provide guidance and detailed advice. We’ve also worked with many of the UK's leading companies to resolve particularly complex transfer pricing problems and implement solutions.

Transfer pricing advice will often involve more than one country. We can offer a tailored consultative service which will help to coordinate your worldwide transfer pricing policies, helping you define your business requirements and develop appropriate tax strategies.

Our Global Coordinated Documentation (GCD) system offers a streamlined alternative that helps multinationals deal with the requirements of multiple jurisdictions in an efficient and coordinated manner.

Execution

Transfer pricing affects a wide range of internal stakeholders, systems and processes. To set up, operate and embed your transfer pricing end-to-end (E2E) requires the seamless operation of your business, finance and tax resources.

Our transfer pricing E2E team includes experts from transfer pricing, tax risk assurance, consulting and tax technology teams. We provide an integrated solution to meet your needs, whether you want to address a specific part of the E2E landscape or full E2E.

Advance Pricing Agreements

To reduce uncertainty on a prospective tax position, we can negotiate Advance Pricing Agreements (APAs) with tax authorities in the UK and overseas.

Since the inception of the APA programme in the UK, we’ve been involved in the negotiation of more than 70 unilateral or bilateral APAs for clients in a wide range of economic sectors.

Download Advance pricing agreements - Removing uncertainty from transfer pricing

Defence and dispute resolution

If HMRC is investigating your transfer pricing we can help with advice on your position or your approach to the defence. HMRC has detailed processes for pursuing transfer pricing enquiries and familiarity with these is often helpful. We have experience both of cases that have been taken to court and those settled privately through negotiation.

We also have extensive experience dealing with transfer pricing disputes involving two or more territories, where we’ve resolved the relevant issue with the government of one or other country without invoking formal (and time consuming) dispute resolution procedures.

Financial services transfer pricing

Since the onset of the financial crisis in 2008, the financial services sector has gone through some major local and global regulatory changes which have had a knock on effect in many of the transfer pricing models for all financial services firms.

Whether you’re in banking, capital markets, insurance or asset management industry, we can help — with sector-specific, locally grounded advice and solutions, including advance pricing arrangements, adapted to the markets you are in.

Transfer pricing of debt

With the global financial crisis impacting credit markets, multinationals have relied more heavily on intercompany self-funding within a group to finance their operations. This high degree of intercompany self-funding and the budget deficits of governments around the world have resulted in an increased focus of tax authorities on the transfer pricing of financial transactions.

The correct application of the transfer pricing legislation for financial transactions has become a top priority for taxpayers. Our network of debt specialists can advise you on the factors to consider when setting an intercompany debt, and the alternatives available. We can also help you with the negotiation of an advance thin capitalisation agreements (ATCA) with HMRC, which could be an effective way to reduce the uncertainty on the prospective tax position of your intercompany debt.

For more information about our debt pricing services, please contact Victoria Horrocks

Business transformation

Transfer pricing can play an important role in exploring business restructuring opportunities to optimise profits. We can help you to realign your business model to take advantage of different tax incentives and can also help you pursue other business structuring opportunities.