Transfer pricing services

Greater transparency, achieved through disclosure requirements and international information exchange, has led to increased audits and regulatory scrutiny. In the UK, the Transfer Pricing Records Regulations 2023, HMRC’s Guidelines for Compliance (GfC7), and the latest consultation (April 2025) reflect a trend towards stricter enforcement.

Global initiatives such as country-by-country reporting (CbCR) and the OECD’s Pillar One and Pillar Two frameworks further complicate compliance. In this environment, strategic, well-documented transfer pricing planning is essential to mitigating costly disputes.

How our transfer pricing specialists can support

As part of a truly global network, operating in over 100 countries, we can provide the knowledge and resources necessary to understand your transfer pricing obligations and maintain compliance. Our team offers tailored guidance to design, review and help improve transfer pricing policies, effectively balancing risk management with your commercial priorities.

Our transfer pricing services include

• Transfer pricing review and implementation

  We provide tailored guidance for navigating or refining transfer pricing requirements, helping manage risks and identify opportunities through strategic planning and implementation. This includes policy design, risk assessment, restructuring strategies, dispute resolution, and strong governance to reduce compliance risk.

• Compliance with transfer pricing requirements

  Many jurisdictions require annual transfer pricing documentation to align with the arm’s length standard. OECD’s CbCR, Master File, and Local File create complex documentation requirements. We streamline compliance with technology-enabled solutions, ensuring accuracy and risk mitigation.

• Dispute prevention and resolution

  Scrutiny can lead to audits, double taxation, and legal disputes. We help clients mitigate risks through expert analysis, negotiations with tax authorities, and strategic dispute resolution frameworks.

• Financial transactions

  Intercompany financial transactions, loans, cash pooling, and working capital advances are essential for global operations but face increasing scrutiny. We help assess compliance, ensuring alignment with evolving regulations and minimising risks.

• Intellectual property

  Precise IP valuation is essential for tax compliance and strategic planning. We provide expert assessments to optimise asset strategies and regulatory alignment.

• Restructuring

  Cross-border restructuring can drive growth but poses transfer pricing risks. We develop tax-efficient policies that ensure compliance and long-term stability.

Sectors being impacted by transfer pricing

Financial services

Financial institutions must navigate cross-border financing, asset management, and regulatory scrutiny while maintaining compliance with evolving transfer pricing rules. We provide expert guidance, tailored risk assessments, and strategic solutions to streamline operations and future-proof transfer pricing approaches.

Technology, media and communications

The rapidly evolving technology, media and communications industry faces complex transfer pricing challenges, particularly in valuing and managing IP. We help businesses assess fair market value, structure cross-border transactions, and ensure compliance with global tax regulations.

Our tools and solutions to support you with transfer pricing

We leverage cutting-edge technology, industry-leading databases, and proprietary tools to deliver reliable, efficient, and insightful transfer pricing solutions. Our advanced resources help empower clients to navigate the complexities of the ever-changing global tax landscape with confidence and accuracy.

• Smartscreen BM

  Our proprietary AI-driven tool, Smartscreen BM, is designed to streamline the process of evaluating comparable companies for transfer pricing analysis. By filtering out less relevant data points, the tool allows us to focus on the most comparable companies, enabling more detailed and accurate analyses. This enhances the consistency and precision of our comparability assessments, ultimately helping clients make informed decisions faster and more effectively.

• Transfer pricing resources

  We leverage industry-leading databases, including S&P Capital IQ Pro, Moody’s Orbis, Bloomberg Terminal, and Royalty Range, to support robust transfer pricing analysis. These tools provide comprehensive financial, industry, and benchmarking data for compliance and strategic decision-making.