Transfer Pricing Services

Transfer Pricing Compliance Solutions

Transfer pricing refers to the body of domestic and international rules, regulations and best practice guidance that help determine how the intra-group business activities of a multinational enterprise should be internally priced and consequently how much tax it should pay in the jurisdictions in which it has business activities.

The transfer pricing rules exist to arrest a potential mischief that could take place should a multinational enterprise choose to price its intra-group business activities in such a way as to gain a tax advantage in a particular jurisdiction. 

At the core of the transfer pricing rules is the concept of the arm’s length principle. This principle essentially provides that there cannot be a tax advantage where intra-group business activities are priced on arm’s length terms. In other words, a multinational enterprise must be careful to conduct and price its intra-group business activities as if there was no relationship at all. Further, the rules require taxpayers caught by the rules to document and defend the arm’s length nature of their pricing policies.    

Trusted Transfer Pricing Business Advisers

We specialise in helping growth companies navigate the plethora of transfer pricing rules that they face globally. These rules will vary in terms of emphasis and practice around the world.

The clients we help can be businesses that are tipping over from being small or medium sized businesses with less than 250 employees worldwide (and less than €50 million consolidated turnover or balance sheet assets of less than €43 million) into large sized businesses that breach these thresholds; or perhaps more established larger businesses that are re-thinking their transfer pricing models as their businesses evolve.

What our clients have in common is that they are growing and are therefore often businesses entering new markets overseas for the first time or are expanding operations, with the result that they are facing increased transfer pricing scrutiny in multiple jurisdictions. 

We act for clients across a wide array of sectors including:

What we do

We provide transfer pricing compliance solutions for the full business cycle for growth companies. Specifically, we help our clients in the following ways:

  • We assess, appraise and advise on transfer pricing risk globally so our clients can be clear on what their transfer pricing obligations are and how to prioritise transfer pricing risks.
  • We prepare and file transfer pricing documentation evidence that helps clients be compliant wherever they are in the world.
  • We defend clients facing adverse transfer pricing scrutiny and where necessary we negotiate and agree settlements with tax authorities for them.
  • We help clients agree arm’s length prices with tax authorities, so they have certainty ahead of implementing certain transactions.

Global team of transfer pricing specialists

We are a specialist team of transfer pricing economists, lawyers and accountants across the world. We are agile and Partner-led and take responsibility for delivering high quality solutions.

Please contact us to discuss your Transfer Pricing needs and to find out more about how we can assist you.

Get in touch with our experts

If you want to discuss a specific issue, ask us for a quote, or simply find out what we have to offer, please complete the form below and we'll get back to you as soon as we can.

Alternatively, please email us at webenquiries@mhllp.co.uk


Key contact

Senior Tax Manager – Transfer Pricing
Ashish Bhatnagar
+44 (0)20 3486 4513

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Meet the team

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Alison Conley

Head of Retail & Consumer, Corporate and International Tax Partner

Alison was appointed as one of our Tax Partner's in the summer of 2016 and advises clients of both the London City office and Chelmsford.

After training with a big four firm of accountants, Alison specialised in international tax before being made a partner with BDO, going on to lead its Southern region tax team. She returned to the big four as a partner before becoming a director of a specialist tax and business advisory firm focussing on entrepreneurial clients. 

Over her career, Alison has advised corporate clients of all sizes across many business sectors, but she has particularly strong experience in the retail space. 

Alison has also been involved in multiple transactions and deals, where her focus is on ensuring that the tax strategy matches the needs of the company and its shareholders. 

Alison works closely with the corporate finance teams, and with international clients requiring cross-border tax advice. 

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Chris Danes

Tax Partner

Chris has been in the Baker Tilly family his entire career, working in the UK for ten years then moving to Baker Tilly International for many years. In 2019, Chris became a Tax Partner with MHA MacIntyre Hudson – the UK member firm of Baker Tilly International.

Chris uses his deep knowledge of the Baker Tilly International network and relationships with the trusted colleagues in circa 150 countries within the Baker Tilly International Network to support his Large Corporate Clients with their Global Tax needs. Chris’s clients include numerous household names and Fortune 500 companies.

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Chris Denning

Corporate and International Tax Partner

Chris has over 27 years of tax experience and joined MHA MacIntyre Hudson in January 2013 following the merger with HMT Assurance LLP. He joined HMT in 2008 having previously spent nearly 20 years split between PwC and latterly KPMG.

Chris has provided a comprehensive range of advice and expertise for a range of corporate clients, from entrepreneurially owned start ups to large corporate/ multinationals. This includes advising on, for example, mergers and acquisitions, group restructuring, inbound/outbound expansion, CFC’s, PE’s, shareholder planning, employee incentivisation, transfer pricing strategy and compliance and profit extraction/repatriation.

As well as extensive transactional tax expertise Chris has developed an intuitive understanding of the interaction of taxes in relation to the ongoing provision of tax advice and works very closely with his clients in order that he can proactively identify issues and opportunities for tax planning which can be aligned with commercial goals and activities.

Throughout Chris’ career, he has also developed sector experience in hospitality and real estate.

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Ashish Bhatnagar

Senior Tax Manager – Transfer Pricing

Ashish has a work experience of more than 14 years in Transfer Pricing. He joined MHA MacIntyre Hudson in March 2020 as a Senior Manager in the Transfer Pricing team.

He has supported clients in designing and setting-up tax compliant structures by advising on the transfer pricing elements of business change and value chain transformation following the guidance of BEPS Action 8-10.  He is well versed with OECD principles and Transfer Pricing regulations of several countries.

He has worked on unique transfer pricing assignments including Profit Attribution analysis for MNCs constituting Permanent Establishments, Cost allocation analysis for Fortune 500 companies, transfer pricing compliances, and planning and optimization opportunities across a wide spectrum of industries.

He is a qualified Chartered Accountant and a member of the Institute of Chartered Accountants of India. He also holds an MBA Degree from Goa Institute of Management in India.

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The continuity with their core specialist sector team and ability to give advice across several areas of support has been key to us working together. - Feefo Holdings Ltd

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Great team to work with; a great cultural fit with our business, knowing when to listen and when to take charge. The quality of professional advice and guidance throughout was essential in making this deal happen. Richard Anderson - Fenmarc Produce