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.

GfC7 Transfer Pricing Guidance in Practice

HMRC has raised the bar on transfer pricing compliance with its GfC7 guidance, making companies reassess their current processes and documentation. Hosted by Peter Zender, Blick Rothenberg Partner Susan Vincent breaks down exactly what’s changed and how organisations should respond from establishing a UK risk lead to refreshing benchmarking studies. In this episode, we cover:

Requirements that HMRC’s GfC7 guidance creates for organisations
The International Controlled Transactions Schedule best practice
Practical steps organisations should take to comply with this guidance
Common missteps in documentation and how to avoid severe penalties
Check out our Visual Aid for notes on the episode

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Transfer Pricing – Aligning tax strategy with business goals

With the introduction of the 2023 Transfer Pricing Records Regulations, GfC7, and new draft legislation, transfer pricing is currently a hot topic in the UK with rules continuously evolving.

This makes it more challenging to stay up to date alongside the ongoing shifts in the macroeconomic environment that can impact business supply chains and intercompany transactions.

As a result, it is crucial to ensure that your transfer pricing methodologies accurately reflect the current business landscape and regulations.

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An Overview of the OECD MEMAP

On 2 February 2026, the Organisation for Economic Co-operation and Development (OECD) published their updated Manual on Effective Mutual Agreement Procedures (MEMAP). The MEMAP strengthens global guidance on resolving cross border tax disputes through the Mutual Agreement Procedure (MAP). Key enhancements in the 2026 edition include:

Pre-MAP phase
Greater emphasis on transparency
Timelines
Functional Independence
Dispute Prevention

Gary Mills and Urmi Sen look at the OECD Manual and discuss the key enhancements and the overall impact for taxpayers.

Our people, your partners

Training whilst working at Blick Rothenberg

Our team of advisers brings decades of experience in helping multinational companies of all sizes manage their transfer pricing affairs.

We aim to provide bespoke, high-quality transfer pricing advice, tailored to meet your specific business needs.

As a member of Allinial Global, a prominent association of accounting and advisory firms with over 260 member firms in more than 100 countries, we are well-positioned to assist with transfer pricing matters from a global perspective.

We will collaborate with you to understand your current and future global business supply chain operations, ensuring that your transfer pricing is proactively managed, compliant, and easy to handle.

This will allow you to focus on your business operations without the risk of inadvertently breaching transfer pricing regulations.

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.

Webinar Replay

Transfer Pricing – Latest updates

Transfer pricing is a hot topic in the UK at the moment, with HMRC releasing GfC7 in September 2024 and new draft legislation in April 2025.

Susan Vincent, Andy Briggs, Alejandro Abad Algarra, and Gary Mills discuss the latest developments for staying on top of how it could impact your business.