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Transfer Pricing

Our award winning team has substantial experience of transfer pricing projects and helps to develop and implement robust and pragmatic solutions for their clients. The team consists of individuals with backgrounds from international professional service firms as well as HMRC and works closely with the market leading FTI Consulting economic consulting practice.

In particular, the transfer pricing environment has been undergoing significant change in relation to OECD base erosion and profit shifting (“BEPS”) programme that has included a review of transfer pricing. Going forward, multinational groups will be required to provide greater transparency of their operations and tax profile in the countries where they operate. In addition, greater scrutiny of the tax affairs of multinational groups is to be expected.

The FTI Consulting Transfer Pricing team draws on the unparalleled experience of our more than 120 economists who price complex commercial and financial transactions, undertake valuations of intangibles and stand as expert witnesses in litigation cases.

We are fully engaged with the BEPS programme and actively participate in OECD consultations on transfer pricing matters. Also, the team advises on the post BEPS environment providing practical solutions to ensure adherence to new OECD guidance.

Our team provides a fully integrated transfer pricing service supported by our deep international tax and economic expertise. As a member of the WTS Alliance, we have the capability to provide multijurisdictional transfer pricing support to our clients.

As FTI Consulting is free from audit and assurance client relationships, we will always be positioned to defend a client’s transfer pricing policies and advise them on an ongoing basis.

Our Services Include:

  • Advising on transfer pricing strategy which aligns tax compliance and business objectives
  • BEPS impact analysis and advising clients on solutions compliant with the latest OECD recommendations
  • Preparation of master file (global/local) documentation, including reviewing country-by-country reports and performing risk analysis
  • Managing disputes with tax authorities
  • Restructuring and/or acquisition advisory
  • Advance Thin Capitalisation Agreements (“ACTAs”) and Advance Pricing Agreements (“APAs”)
  • Pricing complex intra-group financial arrangements
  • Valuing intangible assets, for licensing or sale purposes
  • Optimising the tax efficiency of supply chains
  • Undertaking Diverted Tax Profits (“DPT”) risk reviews and mitigating DTP risk
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