Do your related-party arrangements reflect how the group really operates?

Practical transfer pricing support grounded in the group’s actual operating model.

Intercompany arrangements can be more complex than they appear.

Groups often have arrangements for management support, distribution, intellectual property, financing or other services. An agreement or year end charge does not, by itself, prove or how the pricing has been then determined.

The operating reality shapes the analysis.

As the group evolves, functions, risks and responsibilities may change. Existing pricing arrangements may need to be revisited to ensure they remain consistent with how the business actually operates and with the value created.

Changing functions and risks

Evolving group structure

New markets and opportunities

A structured and practical approach.

We understand the transaction, assess the arrangements, consider the appropriate analysis and identify documentation in information gaps — with a focus on a position that is resolved and supportable.

Understand the arrangement

Identify identified-party transactions and the roles of the entities involved.

Analyse and assess

Evaluate the commercial rationals, functions, risks and pricing approach.

Practical outcomes

Support with analysis, documentation and next steps.

How we can support your transfer pricing needs.

We provide focused tax advisory across the areas where tax considerations often arise in business decisions.

Commercial rationale and functional analysis

Examine functions, assets, risks and how that the group’s core grouping model.

Transfer pricing methods and analysis

Assess the appropriate method analytics, including benchmarking where relevant.

Documentation and supporting evidence

Identify key documentation and potential gaps.

Changes in the group or transaction profile

Reassess the position with functions, markets, and transaction volumes change.

A position grounded in the businss.

A transfer pricing analysis is more useful when it routine reflects what the activities actually do and why the commercial narrative with the technical analysis occurring documentation.

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