UK Transfer Pricing Consultants

700 projects completed in 5 years

UK Transfer Pricing Strategy

Transfer pricing strategy starts with understanding how your business actually creates value. We design structures and agreements that align commercial reality with HMRC expectations. Our work focuses on getting the fundamentals right - so your UK operations run with clarity, confidence, and long-term certainty. No templates, no guesswork, just practical strategy.

UK Transfer Pricing Policy Design & Implementation

We build pricing policies that fit how you actually operate - not generic frameworks. Tailored to HMRC guidance and OECD standards, our approach strengthens governance, ensures consistent transfer pricing policies, and creates positions that hold up under scrutiny from tax authorities.

UK Value Chain Analysis & Substance Alignment

We map where value actually gets created in your business - who does the work, who takes the risk, who owns the assets. This analysis strengthens compliance, builds transparency, and reduces HMRC exposure by showing your transfer pricing reflects genuine economic reality, not just theory on paper.

Your intercompany agreements need to tell a story that makes sense. We draft agreements that accurately reflect your functions, risks, and assets - so when HMRC asks questions, the answers are already there. This strengthens audit readiness and ensures consistent transfer pricing documentation across your global operations.

Intercompany Agreement Review & Drafting

Supported Vinted's shift from ($118m) in 2022 to $17m in 2023

UK Transfer Pricing Compliance

Compliance isn't just about ticking boxes - it's about being ready when HMRC comes knocking. We handle the documentation, benchmarking, and risk assessments that keep you safe. Get this right and you'll sleep better knowing an audit won't derail your business or drain your resources.

Benchmarking & Economic Analysis for HMRC Compliance

We identify where HMRC is likely to look - and whether you're ready. Our assessment uncovers governance gaps, documentation weaknesses, and audit risks. Then we give you actionable insights to strengthen your position and build a framework that actually holds up when tested.

UK Transfer Pricing Risk Assessment & Compliance Reviews

We prepare the transfer pricing documentation HMRC expects to see - Master File and Local File, fully aligned and defensible. Our documentation provides clear evidence of your methodology, is audit-ready, and creates a robust foundation that stands up to scrutiny. The result: compliant, consistent documentation you can rely on with confidence in any HMRC enquiry.

UK Master File, Local File & Concurrent Documentation

We find comparable companies that actually look like yours - not just database matches. This evidence helps you defend your pricing to HMRC, strengthens your position, and keeps you compliant with what they expect from your transfer pricing.

Uk Operational Transfer Pricing

Transfer pricing only works if it's executed properly in practice. We build the processes, controls, and dispute mechanisms that keep your pricing consistent and compliant day-to-day. The goal is transparency, accuracy, and the confidence that comes from knowing your transfer pricing actually works.

Operational Transfer Pricing for UK Businesses

Transfer pricing isn't just an annual exercise. We build processes and controls that keep your transfer pricing compliant month-to-month. Our tools enhance accuracy, streamline workflows, and reduce HMRC risk by making transfer pricing part of how you operate, not something you do once a year.

HMRC Audit Defence & Dispute Resolution

HMRC audits are stressful. We've been through hundreds. We provide tactical positioning, technical analysis, and direct engagement with tax authorities to resolve issues efficiently and protect you from double taxation and penalties that could impact your business.

Our team guide you through APA and MAP processes to secure long-term certainty and prevent double taxation. Our structured approach and direct negotiations with HMRC and overseas authorities help you achieve sustainable, predictable pricing outcomes for your business.

UK Advance Pricing Agreements - APAs & MAP

Long-term Transfer Pricing Partner

Vinted

• Weekly calls for the last 5 years focused on transfer pricing, cross-border scaling, accounting and M&A integration

• 200+ projects delivered across multiple workflows and many stakeholders

• Coordination of work through a Project Management platform

• Four M&A integrations, two spin-offs

• Intercompany transaction calculation tool for accounting ease and financial oversight of the group entities

• Supported shift from 111m USD loss (2022) to 89m USD profit (2024)

Docplanner

• Monthly calls for last 4 years focused on international tax, financial audit support, finance, M&A, etc.

• 100+ projects delivered over four years

• Designed and maintained a streamlined global transfer pricing structure

• Intercompany transaction calculation tool for accounting ease and financial oversight of the group entities

Frequently asked questions

What is transfer pricing and why does it matter for UK businesses?

Transfer pricing is the price charged for transactions between related companies – services, goods, IP, or financing. HMRC requires these to follow the "arm's length principle" (what independent companies would charge). Getting it wrong risks tax adjustments, penalties up to 30%, and double taxation. It's critical for any UK business with overseas subsidiaries or related entities.

What triggers an HMRC transfer pricing audit?

HMRC targets high-value cross-border transactions (£10m+), persistent UK losses, payments to tax havens, IP arrangements, high-risk sectors (tech, pharma, e-commerce), business restructuring, and lack of documentation. Even smaller businesses can be audited if they have related party transactions with low-tax jurisdictions or show profit-shifting patterns.

Do I need transfer pricing if I'm under £10m turnover?

Yes, if you have cross-border related party transactions - there's no size exemption. HMRC's enforcement focus is larger businesses, but you still need to demonstrate arm's length pricing. For smaller businesses, simplified documentation covering key transactions is often sufficient. Invest in full documentation if you're approaching £10m, planning M&A, or have complex structures.

What is an arm's length price, and how do I prove it to HMRC?

An arm's length price is what independent, unrelated companies would charge in comparable circumstances. To prove it to HMRC, you need comparable data – either from external benchmarking studies, industry databases, or third-party quotes. The more robust your comparables and the better documented your methodology, the stronger your defence in an HMRC enquiry. This is why contemporaneous documentation is essential.

How does transfer pricing affect my group's tax position?

Transfer pricing directly determines where profits are taxed within your group. Aggressive pricing can shift profits to low-tax jurisdictions (which HMRC will challenge), while conservative pricing may result in overpaying UK tax. The goal is arm's length pricing that reflects genuine value creation - this minimises audit risk and ensures fair tax allocation across your group. Proper transfer pricing also prevents double taxation when multiple countries adjust the same transaction.

London office

iValuechain Ltd
20 St Dunstan's Hill
London, EC3R 8HL,
United Kingdom

Hours
Monday - Friday
9am - 6pm

Contacts
+44 20 3795 2391
hello@ivc-consulting.com