Transfer pricing services
In today’s interconnected business landscape, multinational enterprises face increasingly complex challenges when managing cross-border transactions and ensuring compliance with evolving tax regulations. Our comprehensive transfer pricing services provide the strategic guidance and technical expertise you need to optimise your global tax position whilst maintaining full regulatory compliance across all jurisdictions.
Why transfer pricing excellence matters for your business
As tax authorities worldwide intensify their scrutiny of intercompany pricing arrangements, organisations cannot afford to operate with outdated or inadequate transfer pricing policies. The financial and reputational risks of non-compliance have never been higher, with penalties reaching millions of pounds and potential damage to stakeholder confidence.
Our transfer pricing specialists understand that effective transfer pricing strategy requires more than mere compliance; it demands a sophisticated understanding of international tax frameworks, economic analysis methodologies, and the commercial realities of your business operations.
Comprehensive transfer pricing solutions
Strategic planning and implementation
Our transfer pricing implementation services begin with a thorough assessment of your current arrangements and identification of potential risk areas. We develop robust transfer pricing policies that align with your business objectives whilst satisfying the requirements of tax authorities across multiple jurisdictions.
Key components include:
- Comprehensive risk assessment of existing intercompany arrangements
- Development of arm’s length pricing methodologies
- Creation of sustainable transfer pricing strategy frameworks
- Integration with broader tax and business planning initiatives
Transfer pricing documentation and compliance
Meeting compliance requirements across multiple jurisdictions requires meticulous attention to detail and deep understanding of local regulations. Our transfer pricing documentation services ensure you maintain robust defence files that satisfy tax authorities whilst supporting your commercial arrangements.
Our documentation services encompass:
- Master File and Local File preparation for country-by-country reporting
- Transfer pricing documentation requirements analysis for each relevant jurisdiction
- Ongoing maintenance and updates to reflect business changes
- Transfer pricing documentation quality assurance and regulatory alignment
Methodologies and economic analysis
Selecting appropriate transfer pricing methodologies is crucial for demonstrating arm’s length compliance. Our economists and tax specialists conduct rigorous economic analysis to support your pricing decisions and provide robust defence against potential challenges.
Technical capabilities include:
- Benchmarking studies using comprehensive databases
- Intangible assets valuation and profit allocation analysis
- Intellectual property valuations for licensing arrangements
- Complex profit allocation modelling for unique business arrangements
Advanced transfer pricing services
Advance pricing agreements and proactive planning
Advance pricing agreements (APAs) provide certainty and reduce compliance costs by securing prior approval from relevant tax authorities. Our APA specialists guide you through the complex negotiation process, ensuring optimal outcomes whilst maintaining operational flexibility.
APA services include:
- Feasibility assessments for potential advance pricing agreements
- Technical case preparation and submission
- Multi-jurisdictional advance pricing agreements coordination
- Post-APA monitoring and compliance maintenance
Controversy and dispute resolution
When transfer pricing controversy arises, rapid and expert intervention is essential. Our dispute resolution team combines technical expertise with negotiation skills to achieve favourable outcomes whilst preserving business relationships.
Dispute resolution capabilities:
- Transfer pricing audits defence and management
- Transfer pricing adjustments analysis and challenge
- Mutual agreement procedures under applicable tax treaties
- Comprehensive dispute resolution strategy development
Specialised transaction support
Complex intercompany transactions require careful structuring to ensure compliance and optimise tax outcomes. Our specialists provide guidance on pricing arrangements for goods, services, financing, and intellectual property transfers.
Transaction support includes:
- Intercompany agreements design and documentation
- Intercompany transactions pricing analysis
- Tax transparency compliance for complex arrangements
- Integration with tax audits preparation strategies
Industry-leading expertise and global reach
As part of the Kreston Global network, we combine local market knowledge with international expertise to deliver comprehensive transfer pricing solutions. Our specialists maintain current knowledge of evolving regulations and possess deep understanding of tax authorities’ approaches across multiple jurisdictions.
Our competitive advantages:
- Proven track record in complex transfer pricing implementation projects
- Recognised expertise in intellectual property valuations and intangible assets management
- Strong relationships with tax authorities facilitating effective dialogue
- Comprehensive understanding of tax treaties and international tax frameworks
Frequently asked questions
How do changing tax regulations affect our transfer pricing policies? Global tax regulations continue evolving rapidly, particularly following OECD BEPS initiatives. Regular review and update of transfer pricing policies ensures continued compliance and optimisation opportunities. Our specialists monitor regulatory developments and provide timely guidance on necessary adjustments.
What documentation is required for country-by-country reporting compliance? Country-by-country reporting requirements vary by jurisdiction but typically include Master Files, Local Files, and annual CbC reports. Our transfer pricing documentation services ensure comprehensive compliance whilst maintaining operational efficiency.
How can advance pricing agreements benefit our organisation? Advance pricing agreements provide certainty regarding tax authorities’ acceptance of your transfer pricing arrangements, reducing audit risk and compliance costs. They’re particularly valuable for complex or high-value intercompany transactions.
What should we expect during a transfer pricing audit? Transfer pricing audits involve detailed review of your pricing methodologies, documentation, and commercial arrangements. Robust transfer pricing documentation and proactive risk assessment significantly improve audit outcomes and reduce potential transfer pricing adjustments.
How do we ensure tax transparency whilst protecting commercial confidentiality? Effective tax transparency strategies balance regulatory compliance with legitimate commercial confidentiality concerns. Our specialists develop disclosure approaches that satisfy tax authorities whilst protecting sensitive business information.
Secure your global tax position today
Don’t allow transfer pricing compliance to constrain your international growth ambitions. Our comprehensive services provide the expertise and support necessary to navigate complex global tax requirements whilst optimising your tax position.
Contact our transfer pricing specialists today to discuss your specific requirements and discover how our proven methodologies can strengthen your global tax compliance framework. With increasing scrutiny from tax authorities worldwide, proactive planning and expert guidance have never been more valuable.
Ready to enhance your transfer pricing strategy? Speak with our experts now to secure your consultation and take the first step towards optimised global tax compliance.
The Global Transfer Pricing Group
Further reading
Arm’s length principle—is it out of reach?
The arm’s length principle challenges traditional tax rules as multinationals integrate. Explore reforms to keep ALP relevant.
Economic substance in Transfer Pricing
Explore how economic substance in transfer pricing ensures compliance, supports sustainable tax strategies, and strengthens multinational business operations.
