Transfer Pricing

Transfer pricing continues to be one of the most complex and fast-changing areas of international tax. In the UK, HMRC maintains a sustained focus and scrutiny on multinationals’ cross-border arrangements, particularly where significant value is created or risk is assumed.

Against this backdrop, transfer pricing is also an opportunity to drive business value and support growth. We help clients unlock opportunities to improve the efficiency and robustness of their transfer pricing models, while proactively managing tax risk.

Our team advises on the full spectrum of transfer pricing matters — from policy development and implementation through to documentation, defence and dispute resolution. We bring this expertise to the most complex issues, including controversy management and expert witness services, transfer pricing and arbitration work.

We support businesses of all sizes, from owner-managed businesses to FTSE 100 companies. Our advice is pragmatic, risk-based and aligned with current OECD and HMRC guidelines, ensuring your arrangements are efficient, robust and defensible.

Alongside the expertise of our global Tax Advisory team, we are uniquely positioned to provide multijurisdictional advice and fully integrated transfer pricing service. As FTI Consulting is free from audit and assurance client relationships, we can defend a client’s transfer pricing policies and advise them on an ongoing basis.  

Our areas of focus include the following:

• 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 and exit taxation. 
• Financial Transactions: Pricing of intercompany financing arrangements including for structural debt, upstream loans, cash-pooling and other intra-group financing arrangements.
• Disputes: Identifying and resolving transfer pricing risks identified as part of due diligence processes, managing transfer pricing audits with tax authorities including the Profit Diversion Compliance Facility (“PDCF”) with HMRC, negotiating Mutual Agreement Procedures (“MAPs”) and Advance Pricing Agreements (“APAs”).
• Litigation and Arbitration: Standing as expert witnesses in large international tax litigations and arbitrations, offering robust, independent analysis and providing case support and advice.
• 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, comprehensive reviews of existing transfer pricing policies, and planning of new transfer pricing policies.
• Transfer Pricing Documentation: Master File, Local File and Country-by-Country Reporting (“CbCR”) including advising on the most pragmatic way of managing documentation requirements.

Our transfer pricing professionals work closely with FTI Consulting’s Tax Advisory team and draw on the deep expertise of our economic and financial consulting colleagues. This includes experts who price complex transactions, value intangibles and serve as expert witnesses in international litigation and arbitration.

Our Team

Our team brings expertise from working in large accountancy firms as well as HMRC. We are actively engaged in changes to tax and transfer pricing policy, including participation in HMRC’s consultation processes on changes to UK transfer pricing legislation. We work closely with our colleagues in the WTS Global Network and also lead discussions with tax policy makers and speak on the latest transfer pricing developments at the TP Minds International Conference.