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.
We discuss the new anti-profit fragmentation legislation and what it means for SMEs.
Baker Tilly International has created this Country-by-Country Notification Monitor document to support Multi-National Enterprises through the notification process to ensure compliance with the minimum possible burden.
Batanayi is a Partner based in the London office.
Batanayi leads the transfer pricing service line at MHA and has over 18 years of transfer pricing experience in the UK across a broad spectrum of industry sectors including financial services, private equity, funds, manufacturing, media and technology, as well as life sciences and telecommunications.
Batanayi helps clients prepare and defend transfer pricing policies and he has a particular focus on resolving transfer pricing disputes involving complex transfer pricing enquiries. This extends to handling MAP proceedings and agreeing APAs, and ATCAs.Get in touch with Batanayi Katongera
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
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
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.Get in touch with Chris Danes
SilverLining UK very highly recommends MHA MacIntyre Hudson for all your company’s financial accounting needs.Our corporation has worked with MHA MacIntyre Hudson for the last 4 years. They are truly the best at what they do.They continually provide timely and excellent service and go ‘above and beyond' for their client. Their knowledge, communication skills and professional qualifications are of the highest quality and standards. SilverLining UK - Construction Sector
With MHA MacIntyre Hudson’s support, our business has been very successful since we started three years ago. Simon Burke - Dalbergia Group