Transfer Pricing

Transfer pricing is a key consideration for any business operating across multiple jurisdictions or engaging in related‑party transactions.

With increasingly sophisticated international rules and heightened scrutiny from tax authorities, it is essential to ensure that intra‑group pricing is robust, well‑supported, and fully compliant with arm’s‑length standards. Effective transfer pricing management helps businesses meet their obligations, respond confidently to HMRC enquiries and maintain consistent, defensible pricing across their operations.

Transfer pricing legislation requires that transactions between connected entities be priced as if conducted between independent parties. With growing scrutiny from tax authorities and substantial penalties for non‑compliance, businesses must ensure their pricing policies are commercially robust, economically justified, and supported by clear documentation.

The compliance landscape has become more demanding in recent years due to OECD BEPS measures, country‑by‑country reporting requirements, and enhanced documentation standards. These developments place greater emphasis on profit attribution, commercial substance, and purpose, making specialist expertise vital for managing risk and ensuring full compliance.

How we can help

We work alongside our clients and, where appropriate, their specialist transfer pricing advisers to provide practical support from a UK perspective. Our role typically focuses on reviewing existing arrangements and helping clients ensure they remain commercially sensible, well-evidenced, and aligned with UK requirements.

In particular, we can assist by:

• Reviewing your transfer pricing documentation to confirm that it is consistent with UK rules and HMRC expectations, and identifying any gaps or areas requiring further support.
• Commenting on your intra-group pricing policies to help confirm they reflect the arm’s length principle and are clearly explained, well-supported, and capable of being evidenced.
• Reviewing intra-group charges, recharges and management fee arrangements from a UK perspective, including how they interact with corporation tax computations and other UK reporting obligations.
• Considering the wider UK tax implications of related-party transactions, such as interaction with the corporate interest restriction, controlled foreign companies and hybrid mismatch rules.
• Supporting you in responding to HMRC enquiries or information requests relating to transfer pricing matters, drawing on our experience of managing HMRC correspondence across other corporate tax areas.

Where a client requires benchmarking analysis or specialist economic input, we are happy to coordinate with appropriate third-party providers to ensure the overall position is coherent and that the UK reporting and compliance requirements are properly addressed.

Focused on Your Objectives

Our approach is shaped by your priorities, whether achieving full regulatory compliance, minimising double-taxation risk, or ensuring that intra-group arrangements are supported by clear and consistent documentation. By focusing on a practical UK review of your transfer pricing policies, pricing and documentation, we can help you identify and address any areas of weakness before they attract HMRC attention. You can be confident that, with our input, your transfer pricing arrangements will be sense-checked from a UK standpoint and better placed to withstand scrutiny.