Specialised in UK & Cross-Border Taxation

Core Advisory

Transfer pricing documentation

When companies in the same group trade with each other across borders, those transactions must be priced as if between independent parties, and that position must be documented. We help groups set, support and document their transfer pricing.

Good documentation is not box-ticking: it is the evidence that protects you if HMRC or another tax authority asks how your intra-group prices were set.

Intra-group cross-border transactions

What we help with

  • Reviewing intra-group transactions (goods, services, financing, IP)
  • Applying the arm's-length principle and selecting an appropriate method
  • Preparing master file and local file documentation
  • Benchmarking support and functional analysis
  • Aligning transfer pricing with your wider international structure
  • Responding to HMRC transfer pricing enquiries

Who it's for

  • International groups with connected entities trading across borders.
  • UK subsidiaries of overseas parents (and vice versa).
  • Businesses that have grown internationally without formal documentation in place.
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Frequently asked questions

Does my business need transfer pricing documentation?

If you have transactions between connected entities, particularly cross-border ones, there is likely to be a transfer pricing requirement. We can assess your exposure and what level of documentation is proportionate.

What happens if we don't have documentation?

Without it, you are exposed to adjustments and penalties if a tax authority challenges your intra-group pricing. Contemporaneous documentation is your first line of defence.

Why I&I: you work directly with M Imran (ACA, FCCA & ADIT), a senior specialist in UK and cross-border tax. Partner-led attention, plain-English advice, and the international expertise to handle this in-house rather than refer it out.

Related services

Speak to a specialist

Speak with M Imran (ACA, FCCA & ADIT) directly about your transfer pricing position. One senior specialist, start to finish: no hand-offs, no call centres.

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Call / WhatsApp: +44 7883 542629 · Email: [email protected]