Transfer pricing

There are numerous internal and external factors that affect your group’s transfer pricing arrangements. Changes can be driven by international expansion, commercial reorganisations, acquisitions or disposals, high growth or legislative change. 

You need to give your transfer pricing policy and compliance significant care and attention. You should regularly review and update transfer pricing policies to reflect commercial and operational changes. Your business need to have documentation that articulates the alignment between value creation and where profits are taxed. 

Failing to manage transfer pricing effectively can lead to: 

• Local tax audits and reassessments, additional penalties and interest 
• Double taxation with no relief available under tax treaties 
• Costly and time-consuming disputes with tax authorities 
• Reputational damage 

Our Transfer Pricing team has technical expertise in tax, law, economics and finance. We have experience from a range of settings including professional services, industry and revenue authorities around the world. This depth and diversity of knowledge delivers innovative thinking and robust transfer pricing solutions. We will work with you to find the most efficient structures, mitigate tax risk and develop transfer pricing models that evolve with your business. 

We can help you articulate the policies and information required for the Master file as well as using a modular approach for Local Files to provide cost-effective coverage. Our approach will help you mitigate the risk of challenges and penalties. 

We are a key member of the BDO international network that includes dedicated transfer pricing experts in more than 90 countries. You benefit from that collective knowledge and experience. We will build a close relationship with you in the UK to bring you the benefit of our global reach and knowledge. 

We will also help you adapt transfer pricing policies as new rules emerge or your business circumstances change. We can support you with analysis and articulation of your value chain, Advance pricing Agreements (APAs) and transfer pricing risk assessments as well as efficient dispute resolution. 

We bring together commercial and tax expertise to deliver you the most effective and productive value chain analyses. You will also benefit from our investment in understanding the relevant issues, opportunities and your business environment.  

We have extensive experience of supporting clients interacting with tax authorities. We have successfully obtained APAs in multiple territories and will assist you throughout the process. Mutual Agreement Procedure (MAP) is a process that authorises tax authorities to communicate with each other directly for the purpose of resolving an issue to avoid double taxation. We have in-depth experience of the MAP application process across our global practice and can support you to seek a satisfactory resolution to any tax authority dispute.  

If a tax authority challenges your transfer pricing, this can lead to a long and costly dispute. Our extensive experience of interacting with tax authorities across the globe enables us to adapt our approach to specifically meet the requirements of the relevant territory on a case-by-case basis. We are confident that we can reduce your costs and mitigate risk. 

In the UK, we work with clients to effectively manage their obligations as set out by HMRC in their TP guidelines for compliance. 

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