Trading between your own entities? The price has to hold up.
When a UK and a US entity in the same group buy, sell or lend to each other, tax authorities expect those dealings to be priced as if between strangers — and documented. We set defensible pricing and structure the group so it stands up on both sides.
Intercompany dealings under a microscope
Transfer pricing is where cross-border groups draw the most scrutiny. Both HMRC and the IRS expect intra-group transactions — goods, services, IP, financing — to meet the arm’s-length standard and to be backed by documentation. Get it wrong and you face adjustments, double taxation and penalties. We build pricing you can defend and keep the paperwork ready.
Pricing and structure that stand up
Three steps, one team
Map the intercompany flows
We identify every dealing between your entities — sales, services, licences, loans — and where value is really created.
Set defensible pricing
We apply the right method to each flow, document the reasoning, and align it with the group’s structure.
Document & maintain
We produce the documentation both authorities expect and keep it current as the business changes, so you’re ready if questions come.
The things clients ask first
Do we really need transfer-pricing documentation?
If entities in your group transact with each other across borders, very likely yes. Both HMRC and the IRS can ask you to show your pricing is arm’s-length, and thresholds and requirements vary — we’ll confirm what applies to you.
What happens if our pricing is challenged?
An authority can adjust the profit, which may create double taxation and penalties. Good documentation and a sound method are what reduce that risk — and treaty mechanisms can relieve double taxation where it arises.
Can you structure where our IP sits?
We can advise on it as part of structuring, but IP location is high-stakes and fact-specific. We’ll model the options and escalate the significant decisions for partner review before anything is implemented.
Make your intercompany pricing defensible.
A free consultation, no obligation. Tell us how your entities trade with each other and we’ll flag the exposure — with a fixed price before any work begins.
