What is transfer pricing?

Transfer pricing is the requirement to apply arm’s length terms to transactions between group companies, this being determined based on comparable transactions between independent companies.

Transfer pricing solutions for your business

Are you a UK group company that engages in transactions with other members of the group?

Although UK transfer pricing is only generally mandatory for groups or companies with more than 250 employees, it can still be good commercial practice to ensure that intra-group services provided are charged for at commercial rates and the transfer pricing obligations for many other countries, such as the US, do not provide an exemption on account of size. Following the OECD’s introduction of the BEPS project - Base Erosion and Profit Shifting – to ensure groups do not artificially shift profits to low-tax jurisdictions it’s crucial you get the right advice in relation to transfer pricing.

Sounds complicated? It needn’t be. Let us do all the hard work so you can concentrate what you’re good at doing, running your business.

Why Kingston Smith?

Our team of tax professionals will…

We will work with you to capture and analyse the necessary information in relation to your intra-group transactions, focussing on the functions performed, risks assumed and assets employed in relation to the services provided. This will then enable us to appropriately ‘benchmark’ the transactions, using OECD approved methods, with comparable transactions between independent enterprises in your industry.

Based on the results of the transfer pricing study, we will make recommendations to ensure that your intra-group pricing structure is optimised from a tax perspective. We can also prepare any intercompany agreements that may be required to document the terms of the intercompany transactions.


Businesses grow, and we’ll be there to support you as you do, giving the most up to date advice on transfer pricing for intra-group transactions. Our clients range from those in two or three jurisdictions to multinational corporates.




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