Transfer Pricing

We evaluate suitable methods and search for comparable independent companies or transactions. The work includes functional screening, financial analysis and adjustments where supportable, with a clear explanation of the selected evidence. Comparable selection is based on comparability, not a desired margin.

The search itself is documented step by step: database screening strategy, quantitative filters, manual review decisions and the reasons individual companies were accepted or rejected. We then compute the arm's-length range from the accepted set, apply working-capital or other adjustments only where they can be defended, and explain how your tested party's result compares.

You receive: A benchmarking report with search strategy, accept/reject matrix, financial analysis and the resulting arm's-length range.

We review existing policies, agreements, reports and actual results for inconsistencies. Particular attention is given to whether the documented arrangement matches conduct, whether charges are supported and whether the financial analysis can be reconciled to the records.

We read your existing files the way a reviewer would: does the functional analysis match what people actually do, are the agreements signed and current, do booked margins fall inside the documented range, and can every intercompany charge be traced to evidence of delivery and benefit? Findings are graded by exposure so remediation effort goes where it matters.

You receive: A findings report with issues graded by significance and a practical remediation plan.

We prepare an entity-focused account of the business and its material controlled transactions. The work connects the functional analysis, method selection, economic analysis and financial information, with supporting schedules that allow the position to be followed and reviewed.

We interview the people who run the business, document functions, assets and risks for each transaction category, justify the method chosen and tie the economic analysis back to the statutory accounts. The file is written so a reviewer can move from the business description to the numbers without gaps, and it is structured for efficient annual updating.

You receive: A complete Local File with functional analysis, method selection, economic analysis and reconciliation schedules.

We help assemble the group-level narrative covering organisational structure, business activities, intangibles, financing and relevant tax positions. We coordinate information requests and review consistency with entity-level documentation, subject to the requirements applicable to the group.

We manage the information-gathering across group companies - legal structure charts, value-chain descriptions, intangible ownership and development, intercompany financing arrangements and existing rulings - and edit the contributions into one coherent document. Consistency checks against each Local File remove the contradictions that reviewers look for first.

You receive: A group Master File aligned with the entity-level documentation and a reusable information-request pack.

We prepare or review the tax and pricing provisions of agreements for services, goods, funding and other arrangements. The focus includes charging mechanics, allocation keys, payment terms and consistency with actual conduct, with legal review coordinated where required.

We translate the pricing policy into contract language: what is supplied, how the charge is calculated, when true-ups occur, who bears which risks and how the arrangement can be evidenced. Where agreements already exist, we flag clauses that contradict the documented policy or the way the parties actually behave, and propose corrected wording for legal review.

You receive: Draft or marked-up agreements with pricing schedules aligned to the documented policy.

We assess proposed operating models and develop pricing policies for distributors, service providers, manufacturers, treasury functions and other group activities. Recommendations consider the allocation of functions and risks, commercial substance and how the policy can be implemented in practice.

A policy is only useful if the finance team can run it. We define the pricing rule for each transaction type, the data inputs it needs, the calculation cadence, who owns monitoring and how new transactions get classified - then test the policy against real numbers before it goes live, so surprises appear on paper rather than in the accounts.

You receive: A written pricing policy with calculation templates, monitoring cadence and implementation checklist.

We analyse intercompany loans, guarantees, cash pooling and extended trade credit. The assessment considers the transaction's nature, borrower circumstances, currency, tenor, security and other relevant terms. A loan benchmark is not automatically suitable for every outstanding trade balance.

The work starts with accurate delineation: is the balance genuinely debt, what are its real terms, and what would independent parties have agreed? We assess the borrower's credit standing, benchmark the interest rate or guarantee fee against market evidence for comparable terms, and document why the chosen reference data fits the transaction under review.

You receive: A financial-transactions analysis with credit assessment, rate or fee benchmarking and supporting market evidence.

We review the services performed, recipients' benefits, cost pools and allocation methods. The analysis helps distinguish chargeable services from shareholder or duplicative activities and supports the basis of any markup, with practical documentation of delivery and benefit.

We build the charge from the ground up: which cost centres feed the pool, which activities are excluded as shareholder costs, which allocation keys map cost to benefit, and what evidence shows each recipient actually received something of value. The result is a fee that can be recalculated, invoiced and defended rather than a round number nobody can explain.

You receive: A shared-services study with cost-pool definition, allocation model, benefit evidence file and invoicing basis.

We assess remuneration and other relevant payments using roles, responsibilities and appropriate market evidence. The analysis considers the full compensation arrangement and relevant legal standard, rather than relying solely on the company's overall profitability to justify a payment.

For payments to owners, directors and other connected persons, we document the role actually performed, gather market reference points appropriate to that role and location, and assess the complete package - salary, benefits, bonuses and other entitlements - against the applicable standard, producing a position the business can apply consistently across years.

You receive: A remuneration assessment memorandum with role documentation and market reference analysis.

We help classify reportable transactions, reconcile disclosure schedules and review actual results against the policy. Where a pricing adjustment is indicated, we assess its basis, accounting treatment and applicable procedural requirements rather than assuming every adjustment is permitted.

At year end we compare booked results with the policy range, prepare the disclosure workings so every figure reconciles to the ledger, and - where an adjustment appears necessary - set out the mechanics: which entity books it, the documentation it requires, its accounting entries and the procedural conditions that apply before it can be reflected in a return.

You receive: Completed disclosure workings, results-versus-policy analysis and an adjustment memorandum where required.

We assess the Transfer Pricing implications of moving functions, assets or risks, changing distribution models or reorganising service arrangements. The work identifies relevant valuation or compensation questions and supports transaction planning, documentation and implementation.

Before the reorganisation happens, we map what is actually moving - people, contracts, customer relationships, intangibles, risk - and assess whether the transfer requires compensation and how the post-change pricing should work. We then document the before-and-after arrangements so the file explains the change instead of leaving an unexplained break in results.

You receive: A restructuring analysis covering transferred value, compensation assessment and post-change pricing design.

We help prepare technical explanations, reconcile data and respond to challenges to pricing methods or comparability. Where matters escalate, we provide economic and documentary support alongside appropriately authorised representatives or legal counsel. No outcome is guaranteed.

When a position is challenged, we rebuild the evidential chain: reconciling the questioned figures, stress-testing the original comparables, preparing alternative or corroborating analyses and drafting technical responses that answer the specific challenge raised. Everything is organised so your authorised representatives or counsel can act on it directly.

You receive: Reconciled data packs, technical response drafts and supporting economic analyses for the defence team.

We assess whether an available advance pricing agreement or treaty-based Mutual Agreement Procedure may be relevant. Support can include feasibility analysis, information preparation and technical submissions, subject to jurisdiction-specific availability, eligibility and procedural requirements.

We start with a realistic feasibility view - the transactions suited to certainty procedures, the information burden, indicative timelines and the strength of your supporting analysis - and then help assemble the submission: transaction description, proposed method, critical assumptions and the economic evidence a reviewing authority will expect to see.

You receive: A feasibility assessment and, where pursued, a complete application or submission support pack.