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.
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:
We provide transfer pricing compliance solutions for the full business cycle for growth companies. Specifically, we help our clients in the following ways:
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.
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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.Get in touch with Alison Conley
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.Get in touch with Ashish Bhatnagar
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.Get in touch with Chris Denning
Victoria has been with Macintyre Hudson since 2015, starting as a graduate trainee and qualifying as a chartered accountant in 2018. Subsequently moving from audit into tax, she has been a member of the Transfer Pricing team since 2019.
Victoria manages the compliance and advisory aspects of the transfer pricing practice. Working on a diverse range of clients from listed companies through to growing owner managed businesses experiencing transfer pricing issues for the first time, Victoria works closely with her clients to ensure they have the most appropriate policy in place to suit their needs.
In addition, Victoria is an active member of the Social and Charity committees. Most recently she helped arrange our annual client quiz, in which we raised over £8,000 for the London Air Ambulance.Get in touch with Victoria Jeffs
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
The relationship with MHA MacIntyre Hudson has always been a solid one. The team are able to respond quickly to problems and achieving timescales. Their international network, Baker Tilly International, gives them breadth and the ability to cover overseas issues. - PRISYM ID