Transfer Pricing

Transfer pricing: the challenge

Increasing scrutiny from tax authorities and the wider public means that managing transfer pricing controversy risks as part of managing your company’s overall tax position and its reputation has never been more important.

Whether you’re a tax director, legal counsel, finance director, controller, accountant or a chief executive officer, you must be prepared to respond to the challenge.

What do we mean by ‘transfer pricing’?

Transfer pricing regards the pricing of transactions between associated enterprises of a multinational enterprise group. In practice, transfer pricing affects the allocation of a multinational enterprise group’s profits and therefore the amount of corporation tax to be paid in the jurisdictions in which it has presence.

Is transfer pricing controversial?

Transfer pricing has made the headlines in recent years, as multinationals are being accused by governments, tax authorities and the media around the world that they are artificially ‘shifting profits’ from one jurisdiction to another to reduce their total tax bill. In this current era of increasing transparency, heightened focus on ESG and public scrutiny on the activities of multinationals, it is important to ensure robust transfer pricing policies which align with the business reality of activities and substance.

How our transfer pricing team works with clients

Our tax lawyers, accountants, economists and transfer pricing experts bring together extensive transfer pricing experience gained in market-leading big four firms, international law firms and government. We advise clients across the entire transfer pricing lifecycle – covering planning, valuation, compliance and controversy work – and consider economic, legal and commercial perspectives to provide strategic and forward-looking advice.

Our strength lies in diffusing, handling and resolving transfer pricing controversies, whichever the jurisdictions involved. We strategically combine domestic controversy management options with treaty-based options to reach an optimal dispute resolution outcome. Our broader tax team also includes indirect tax specialists, so we can advise you on the broader tax spectrum where and as appropriate.

As a firm that embraces technology and offers smart solutions, we include bespoke software driven data solutions in our work processes, as needed.

Are you looking to...

• Re-organise your group IP ownership and licencing structure?
• Test your value chain analysis in light of business and regulatory changes?
• Determine your transfer pricing policies regarding financial transactions and other inter-company transactions?
• Prepare audit defence files to proactively manage controversy?
• Risk assess your strategic options in resolving transfer pricing or diverted profits tax audits?

Get in touch

Whatever your transfer pricing needs, we’re confident we can help. We also publish freely available articles on nuances, developments and controversies in transfer pricing. You can browse a selection of our transfer pricing commentary below.