Over recent years, transfer pricing documentation requirements have become increasingly onerous. Although the OECD has provided a common framework for its members, each member retains its own laws, interpretation and transfer pricing document requirements.
In the UK, transfer pricing documentation should include a functional analysis of the group and identify the various levels of risk present in each territory. The price used in intra-group transactions must reflect the 'arm’s length' price; that is, the price that would have been paid if the transaction had taken place between independent third parties.
How we can help
Analysis and review
We will analyse and review the functions and interactions within your group to ensure that the appropriate transfer pricing is in place
Using industry leading tools, we are able to price and substantiate the transfer pricing applied by using benchmarking of comparable service providers. This substantiation is recognised by tax authorities globally
We have experience in preparing UK transfer pricing documentation and, as part of CLA Global, we have local experts around the world to fulfil global transfer pricing documentation requirements
Transfer pricing enquiries are more prevalent than ever before in light of increasingly complex global transfer pricing requirements, the Covid-19 pandemic and challenges around the digital economy. HMRC may challenge transfer pricing as part of a broader corporation tax enquiry, a diverted profits tax enquiry or as part of the profit diversion compliance facility. We can assist and advise on a fair and efficient resolution to any transfer pricing enquiries