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Transfer Pricing

Practical, commercially-focused advice to help you align your transfer pricing model with your business operations, while ensuring compliance with local requirements

Understanding your transfer pricing needs

Transfer pricing needs to be considered when there are transfers of goods, services, intangible property and financing between related parties within a multinational group.

The rules are continuously evolving, both at a domestic and global level, making it challenging to stay up to date. Additionally, ongoing shifts in the macroeconomic environment can impact your business’ supply chain and intercompany transactions. As a result, it’s crucial to ensure that your transfer pricing methodologies accurately reflect the current business landscape.

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How we can help

Our transfer pricing specialists are on hand to support you with the following services:

  • Transfer pricing health check and due diligence services
  • Transfer pricing policy design for UK and overseas operations, including post-acquisition or business restructuring
  • Economic analyses to support transfer pricing policies
  • Permanent establishment reviews and profit attribution
  • Transfer pricing compliance, including preparation of Master File, Local Files, Local transfer pricing reports, Country-by-country reporting, and other records based on local requirements
  • Thin capitalisation and interest rate benchmarking for intragroup financing
  • Dispute resolution, including audit support and Mutual Agreement Procedures
  • Negotiating Advanced Pricing Agreements
  • Implementation assistance, including review of intercompany recharge calculations and intercompany agreements
  • Ongoing support as business operations or tax laws evolve.

In addition, our close alignment with our Corporate Tax, VAT and Customs, and R&D teams allows us to offer a comprehensive, integrated service that addresses all your tax needs.

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