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In the globalised economy, intra-group interactions have become increasingly complex. These range from the physical trading of goods between group entities, inter-company service provision, inter-company financing and the exploitation of intellectual property by trading subsidiaries. The transfer of value must be priced to ensure that each entity recognises the functions performed, assets used and risks borne to therefore report the correct revenue and cost within the appropriate territories.
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.
Transfer Pricing Risk and Optimisation tool
Transfer pricing has been a growing focus for tax authorities globally, but transfer pricing should also be seen as opportunity for significant tax optimisation. Find out more about our Transfer Pricing Risk and Optimisation tool and how you can optimise your policies, stay compliant and manage risk.
How we can help
Analysis and review
Benchmarking
Documentation
Dispute resolution
