International transfer pricing

 

As global tax regulations tighten and scrutiny increases, businesses must ensure their
intercompany transactions are priced in line with the arm’s length principle.

Our international transfer pricing services are designed to help multinational groups achieve compliance, manage tax risk, and align their pricing policies with commercial reality.

Compliance and documentation

 

We assist clients in meeting UK and OECD transfer pricing documentation requirements, ensuring full compliance and audit readiness:

 

✅  Preparation of Local Files and coordination of Master Files in line with BEPS Action 13.
✅  Country-by-Country Reporting (CbCR) support.
✅  Preparation of intercompany agreements and annual TP reports

 

Benchmarking and economic analyses

 

Our benchmarking services establish defensible arm’s length ranges for your group’s transactions:

 

   Comparable studies for management fees, services, royalties, and financing.
   Margin and profit-level indicator (PLI) analysis.
   Application of OECD-approved methods (CUP, Cost Plus, TNMM, Profit Split).

Strategic and advisory services

 

Beyond compliance, we help businesses design transfer pricing policies that align with strategic and commercial goals:

 

✅  Policy design and implementation across global operations.

 

✅  Review of group structures and cross-border efficiencies.

Dispute management and risk mitigation

 

Our team provides:

 

✅  Experienced support for managing tax authority disputes

 

✅  Including HMRC enquiry response and audit defence.

Intangible property and ip planning

 

Our specialists advise on the valuation and pricing of intangible assets, ensuring alignment with OECD DEMPE principles:

 

→   Royalty and licence pricing.
ƒ →   IP transfers and valuation.
ƒ →   Support for innovation incentives such as the Patent Box.

Training and capacity building

 

We offer tailored training sessions for tax and finance teams on:

 

✔   Transfer pricing principles

✔  Compliance

✔  Documentation best practice

Our approach

 

Our multidisciplinary team combines tax, economics, and legal expertise to deliver practical, defensible solutions.

 

We work with clients across sectors to ensure compliance, optimise tax efficiency, and strengthen global value chainsreporting systems.

 

Want to know more?

 

Download our White Paper: International Transfer Pricing: A Practical Guide for UK Business Leaders for detailed insights, including:

A clear explanation of what international transfer pricing is and how it applies to cross-border transactions

An overview of recent UK regulatory changes, including increased reporting requirements and transparency expectations

The most common risks and pitfalls, and how to avoid costly issues later

Practical steps to build a proportionate and robust transfer pricing framework for SME and mid-sized businesses

Let’s get started

 

For a free consultation and analysis of the potential returns you might expect from your projects, contact the ABGi UK Team.