Transfer pricing services

In the globalised economy, intra-group interactions have become increasingly complex. These range from the physical trading of goods between group entities, inter-company service provision, inter-company financing and the exploitation of intellectual property by trading subsidiaries. The transfer of value must be priced to ensure that each entity recognises the functions performed, assets used and risks borne to therefore report the correct revenue and cost within the appropriate territories.

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Over recent years, transfer pricing documentation requirements have become increasingly onerous. Although the OECD has provided a common framework for its members, each member retains its own laws, interpretation and transfer pricing document requirements.

In the UK, transfer pricing documentation should include a functional analysis of the group and identify the various levels of risk present in each territory. The price used in intra-group transactions must reflect the 'arm’s length' price; that is, the price that would have been paid if the transaction had taken place between independent third parties.

Transfer Pricing Risk and Optimisation tool

Transfer pricing has been a growing focus for tax authorities globally, but transfer pricing should also be seen as opportunity for significant tax optimisation. Find out more about our Transfer Pricing Risk and Optimisation tool and how you can optimise your policies, stay compliant and manage risk.

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How we can help

  • Analysis and review

    We will analyse and review the functions and interactions within your group to ensure that the appropriate transfer pricing is in place

  • Benchmarking

    Using industry leading tools, we are able to price and substantiate the transfer pricing applied by using benchmarking of comparable service providers. This substantiation is recognised by tax authorities globally

  • Documentation

    We have experience in preparing UK transfer pricing documentation and, as part of CLA Global, we have local experts around the world to fulfil global transfer pricing documentation requirements

  • Dispute resolution

    Transfer pricing enquiries are more prevalent than ever before in light of increasingly complex global transfer pricing requirements, the Covid-19 pandemic and challenges around the digital economy. HMRC may challenge transfer pricing as part of a broader corporation tax enquiry, a diverted profits tax enquiry or as part of the profit diversion compliance facility. We can assist and advise on a fair and efficient resolution to any transfer pricing enquiries