Transfer Pricing

Understanding and managing transfer pricing is vital in a globalised economy where businesses operate across various jurisdictions. Our specialists have the expertise to advise and guide you on all aspects of transfer pricing.

Talk to us

What is Transfer Pricing?

Transfer pricing is a critical aspect of international business operations, involving the pricing of goods, services, or intellectual property transferred between interconnected entities. These entities typically belong to the same multinational group, often operating in different tax jurisdictions. However, transfer pricing principles can also be applied to transactions within the same jurisdiction when varying tax rates are relevant. The cornerstone of transfer pricing is the adherence to the arm’s length principle, which necessitates that these transactions be priced as if they were carried out between unrelated third parties.

Why Is Transfer Pricing Important?

In the world of international trade, a robust transfer pricing policy is paramount. The significance of transfer pricing extends to businesses planning to expand their operations overseas. Sound transfer pricing advice and strategies are crucial for maintaining compliance and mitigating risks.

Our Expertise in Transfer Pricing

Our specialist team is experienced in all aspects of transfer pricing. We will ensure that you receive comprehensive and practical support to help you remain compliant in this complex area.

Our services include:

  • Risk Factor Review: We conduct a thorough review of risk factors, including but not limited to high-risk business models, consistent losses in low-risk entities, licensing payments to low-tax jurisdictions, and business restructurings.
  • Transfer Pricing Documentation Requirements: Our team provides up-to-date guidance on the latest HMRC documentation requirements for businesses engaged in international trade.
  • Transfer Pricing Methods: We offer expert advice on selecting the most suitable pricing method aligned with your entity’s functions and associated risks. Common methods include Comparable Uncontrolled Price, Resale Price, Cost Plus, Transactional Net Margin, and Profit Split methods.
  • Exemptions from documentation rules: We assist in understanding and applying exemptions from documentation rules that are available for Small and Medium-sized Enterprises (SMEs), dormant companies, charities, and life assurance companies.
  • Self-Assessment: Our team helps taxpayers confirm SME exemptions on tax returns to ensure full compliance with regulatory requirements.
  • HMRC Engagement: We can act on your behalf by liaising with HMRC and handling any inquiries related to transfer pricing.

Transfer Pricing Advice that meets your Corporate Objectives:

Whether your business lacks defined transfer pricing policies or needs a review of existing ones, we can help. Our goal is to ensure that your transfer pricing arrangements align with the latest guidance and meet your corporate objectives.

For groups with established policies, we offer comprehensive reviews and provide recommendations to enhance compliance. Additionally, we have access to a network of local specialists through Alliott Global Alliance to coordinate transfer pricing reviews and documentation in multiple jurisdictions.

Meet the team

View everyone

Related & Other Musings

View all related content

Contact us

Don’t let transfer pricing complexities hinder your international business operations. Contact us today to receive expert advice and support tailored to your unique needs.

    Transfer Pricing
    Clair Dart | Alliotts



    View Clair's profile

    Clair’s experience has been generated over almost 20 years in practice. Over this time Clair has worked closely with clients operating in corporate and not for profit environments. Clair enjoys the technical aspect of the application of tax legislation to make sure clients are compliant, and the practical application to make sure that they are tax efficient. Tax is integral to each structure and to every transaction, Clair specialises in advising on the vital areas of corporate tax, tax reliefs and international VAT. The true value of Clair’s advice is that it is designed to provide solutions and is delivered in terms clients understand.

    Leading and mentoring a talented team of advisors Clair is driving Alliotts tax offering to ensure that it not only meets, but anticipates the needs of ambitious businesses in a global market. As a testament to her leadership skills Clair was awarded ‘Leader of the Year’ at Westminster Business Council’s 2023 Business Awards.


    “Thank you for taking over our accounts and making the process smooth and seamless. We are delighted with the service we have received. You and your team have been helpful, proactive and generally a pleasure to work with. Thank you”

    Erika Moralez-PerezCEO & Commercial LawyerICONOS GROUP

    “I just wanted to say a HUGE thank you for your help this year. It’s been a tough one trying to navigate the changes and I really appreciate your time and patience and for my answering my questions.”

    Amy McLeanTrust ManagerBeauty Backed Trust


    David Gibbs | Alliotts



    View David's profile

    David is an International Corporate Tax specialist. He has over 30 years’ experience in providing commercially focused tax advice and support to a wide range of clients, from technology start-ups to large inward investing corporates.

    A qualified Chartered Accountant, David went on to qualify as a Chartered Tax Adviser and prior to joining Alliotts as a partner in 2014 he held the position of tax partner in Grant Thornton and subsequently in PwC.

    David focuses on providing strategic tax advice to entrepreneurs and privately owned businesses. By investing time in understanding clients and their businesses he is able to provide advice which is practical and appropriate to clients’ circumstances in order to keep taxes to a sensible minimum. He advises on a wide range of taxes including transaction planning, UK outbound and inbound structuring, corporate tax, technology tax reliefs, investor and shareholder planning, capital gains tax and LLPs. David advises both UK and overseas business owners on international tax planning.

    David also specialises in advising individuals and businesses in the media sector on UK film tax credits, video games tax reliefs and other creative sector tax incentives. He also advises on EIS and SEIS.