Transfer Pricing Advisory

Transfer pricing is only effective when it is grounded in commercial reality and supported by documentation that stands up under pressure. We develop intercompany pricing models that reflect how your group actually operates, how value is created and how functions, assets and risks are distributed across entities.

Our work focuses on creating frameworks that are defensible, consistent and aligned with international standards. This includes benchmarking, functional analyses, value chain assessments and the preparation of documentation that tax authorities can understand and rely on. When advance pricing agreements are appropriate, we manage the process from strategy to negotiation, ensuring clarity and predictability for the years ahead.

We approach transfer pricing as a dialogue, not a confrontation. By working constructively with tax authorities, we reduce friction, accelerate resolution and create outcomes that are both compliant and commercially sensible. This approach helps avoid disputes, protects your structure and gives you confidence in cross border operations.

With experience across multiple jurisdictions and access to specialised expertise when needed, we provide a transfer pricing setup that is robust, transparent and aligned with your long term strategy. The result is a system that supports growth, withstands scrutiny and keeps your group moving without unnecessary disruption.

When clients need this

Group reorganisations, intercompany charges, audits, or where a tax authority is questioning your pricing.

What we cover

• Benchmarking and documentation

• Intercompany agreements

• Audit defence

• Rulings and APAs

• Royalty and licensing positioning