Transfer pricing services

Transfer pricing services

“In our experience, transfer pricing rarely becomes an issue because it’s been deliberately misapplied. More often, it’s simply not considered early enough as businesses grow and structures become more complex.”

Makayla Combes, Tax Associate Director

Contact Makayla

Transfer pricing is not just about compliance. It’s about control

For many businesses, transfer pricing only becomes a focus when it is required, whether due to growth, overseas expansion, or external scrutiny.

By that stage, the structure is already in place and the challenge becomes justifying decisions that have already been made.

A more effective approach is to consider transfer pricing earlier, ensuring that transactions between connected parties are both compliant and commercially aligned from the outset.

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The challenge

Transfer pricing sits at the intersection of tax, commercial decision-making and group structure, which is why it is often overlooked until it becomes unavoidable.

We typically see challenges arise where:

Businesses expand into new territories

Group structures become more complex

Intercompany transactions increase in volume or value

Pricing policies have evolved without formal review

In many cases, the issue is not that transfer pricing has been done incorrectly, but that it has not been considered in sufficient detail early enough. As a result, it often becomes a reactive exercise, rather than something that supports better decision-making from the outset.

Our perspective

We do not see transfer pricing as a standalone compliance exercise.

Done properly, it provides clarity over how value is created within a group, how profits are allocated, and how decisions impact both tax and commercial performance.

In our experience, transfer pricing rarely becomes an issue because it has been deliberately misapplied. More often, it is simply not considered early enough, particularly as businesses grow, expand internationally or introduce more complex group structures.

This allows businesses to:

Understand where profits should sit within the group

Align pricing with commercial reality

Reduce exposure to challenge from tax authorities

Create consistency as the business grows

What we do

We support businesses at different stages of their journey, from early-stage structuring through to ongoing compliance and documentation.

Our services include:

Reviewing group structures and intercompany transactions

Advising on appropriate transfer pricing methodologies

Designing and implementing transfer pricing policies

Preparing transfer pricing documentation

Supporting with HMRC enquiries*

Advising on the transfer pricing implications of expansion, investment or restructuring

Much of our work involves helping businesses formalise arrangements that have developed over time, ensuring they remain appropriate as the group evolves.

*Through our international network, we also have access to advisors who can support with overseas tax enquiries.

When to consider transfer pricing

Transfer pricing is often addressed too late. In our experience, it is worth reviewing when:

Expanding into new jurisdictions

Setting up new group entities

Introducing intercompany charges or financing arrangements

Preparing for investment, audit or exit

Experiencing rapid growth or structural change

Taking a proactive approach at these points can prevent more complex issues later.

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Outcomes

A well-considered transfer pricing approach provides:

Greater clarity over group profitability

Reduced risk of challenge from tax authorities

Stronger governance and internal reporting

Confidence during investment or due diligence processes

Transfer pricing is rarely a problem until it is reviewed.

Taking the time to assess your position now can provide clarity, reduce risk and ensure your structure is fit for future growth.

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How we work

We combine technical expertise with a practical, commercial approach.

Rather than producing documentation in isolation, we work with you to understand how your business operates, ensuring that pricing reflects the reality of your activities and supports your wider objectives.

The focus is not just on compliance, but on providing clarity and confidence as your business evolves.

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