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Transfer Pricing
Transfer pricing laws and regulations are becoming more complex than ever, as the tax affairs of multinational businesses face scrutiny from both tax authorities and the public. Amidst a constantly evolving international tax landscape, transfer pricing represents a key risk area for multinational businesses. Amidst the increasing complexity and scrutiny on multinationals’ international tax affairs, we work with our clients to understand, manage, and minimise their transfer pricing risk exposure.
Transfer pricing is also an opportunity to drive business value and support growth. Our team is focused on assisting our clients with forward-thinking and expert led advice to seek continuous opportunities for improvement in the efficiency of your transfer pricing policies whilst proactively minimising your risk exposure. Our team also deals with assisting clients in the most complex areas of transfer pricing and dispute resolution.
Our award-winning team provides a fully integrated transfer pricing service advising clients on all aspects, including developing, documenting, implementing, and defending transfer pricing strategies. We have substantial experience of transfer pricing projects across all sectors and industries and helps to develop and implement robust and pragmatic solutions.
Our team helps clients to take a risk-based approach to their transfer pricing to minimise interruption to the business from transfer pricing changes as well as optimising the end solutions. We advise a range of businesses at different stages of their lifecycle from small and medium sized enterprises (“SMEs”) to large multinationals. The team consists of individuals with backgrounds from international professional service firms as well as HMRC.
How We Help
- Business Transformation: operating model transformation, optimising the tax efficiency of supply chains, transfer of functions, valuing IP for licensing or sales purposes, value chain analysis, exit taxation
- Financial Transactions: Pricing of intercompany financing arrangements including for structural debt, upstream loans, cash-pooling and other intra-group financing arrangements
- Restructuring: evaluating and updating transfer pricing arrangements for businesses in distress
- Risk reviews, Policy Planning and Implementation: practical assistance and solutions for implementing transfer pricing policies, transfer pricing policy reviews and planning
- Transfer Pricing Documentation: Master File, Local File and Country-by-Country Reporting (“CbCR”) including advising on the most pragmatic way of managing documentation
- Disputes: identifying and resolving transfer pricing risks identified as part of due diligence processes, managing Diverted Profits Tax (“DPT”) disputes with tax authorities including the Profit Diversion Compliance Facility (“PDCF”) with HMRC, negotiating Mutual Agreement Procedures (“MAPs”) and Advance Pricing Agreements (“APAs”).
- Litigation: Standing as expert witnesses and providing case support and advice
We are uniquely positioned to provide multijurisdictional advice, providing fully integrated transfer pricing service, alongside the international tax expertise of our wider European Tax Advisory team. As FTI Consulting is free from audit and assurance client relationships, we will always be positioned to defend a client’s transfer pricing policies and advise them on an ongoing basis.
Our transfer pricing experts also draw on the unparalleled experience of the substantial team of economic experts within our wider firm, who price complex commercial and financial transactions, undertake valuations of intangibles and also stand as expert witnesses in litigation cases. We also provide multijurisdictional transfer pricing support to our clients, working closely with our colleagues in the WTS Global international network.
Meet Our Experts
Featured Tax Capabilities
- Corporate Tax Advisory
- Corporate Tax Compliance
- Employment Tax and Reward
- Environmental, Social, and Governance (“ESG”)
- Life Sciences Tax
- Litigation, Arbitration, Tax and Transfer Pricing (“LATTP”)
- R&D incentives, Patent box, and IP Strategy
- Real Estate Tax
- Restructuring Tax Advisory
- Tax Depreciation
- Transaction Tax Advisory
- Transfer Pricing
- Value Added Tax (“VAT”) and Indirect Tax