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:
- Technology
- Financial Services
- Manufacturing & Engineering
- Extractives
- Leisure & Hospitality
- Retail & Consumer
- Private Investors
- Businesses buying or selling smaller businesses
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.
Contact us
Please contact us to discuss your Transfer Pricing needs and to find out more about how we can assist you.
MHA MacIntyre Hudson and the 
